GR L 51306; (July, 1987) (Digest)
G.R. No. L-51306; July 29, 1987
THE PEOPLE OF THE PHILIPPINES, plaintiff, vs. ROLANDO CAMAY, accused.
FACTS
The accused, Rolando Camay, pleaded guilty to the capital offense of robbery with homicide. Following his plea, the trial court meticulously conducted a searching inquiry to ensure the voluntariness and full comprehension of his plea. The judge personally questioned Camay, confirming he understood the nature of the charge and the severity of the death penalty, and he affirmed his plea. Subsequently, the court required the prosecution to present evidence to prove his guilt and the precise degree of culpability, as mandated by procedural rules.
The prosecution presented witnesses, including the victim’s young daughter who testified she saw Camay hack her mother after demanding money. The victim’s husband testified about finding his wife dead and their trunk forced open with P600 missing. A judge identified Camay’s sworn confession. After the prosecution’s formal offer of evidence, the accused, maintaining his plea, chose not to present evidence. The trial court found him guilty and imposed the death penalty.
ISSUE
Whether the trial court complied with the strict procedural requirements when an accused pleads guilty to a capital offense.
RULING
Yes, the trial court faithfully complied. The Supreme Court emphasized that under Section 3, Rule 116 of the 1985 Rules on Criminal Procedure, a court must undertake three steps after a guilty plea to a capital offense: conduct a searching inquiry into the plea’s voluntariness and comprehension; require the prosecution to present evidence proving guilt and precise culpability; and allow the accused to present evidence. This rule codified existing jurisprudence cautioning that even with a valid plea, evidence must still be adduced to establish guilt and aid appellate review.
The records confirmed the trial judge’s strict adherence. He conducted a thorough inquiry, repeatedly ensuring Camay understood the charge and consequences with his counsel’s assistance. He then compelled the prosecution to present corroborative witness testimony and documentary evidence, including a confession. Only after this evidentiary presentation did the court render judgment. Consequently, the Supreme Court affirmed the conviction, finding guilt proven beyond reasonable doubt. However, in line with the constitutional prohibition, the penalty was modified from death to reclusion perpetua, and the civil indemnity was increased to Thirty Thousand Pesos.