GR 150033; (November, 2004) (Digest)
G.R. No. 150033 November 12, 2004
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DANILO ESPIDOL y VILLANUEVA (Deceased), SAGRADO DALACAT y SANTOS, ALFREDO TOMAS y LIMOS (At-large), AND ARMANDO ANIASCO, accused. SAGRADO DALACAT y SANTOS, accused-appellant.
FACTS
Accused-appellant Sagrado Dalacat, along with others, was charged with Robbery in Band with Homicide for staging a hold-up at a business establishment in Vigan, Ilocos Sur, on October 14, 1998, resulting in the death of Hipolito Bagay and the taking of P1.2 million. Initially pleading not guilty, Dalacat underwent trial where the prosecution presented witnesses, including driver and state witness Virgilio Corpuz. Corpuz testified that he drove the group, including Dalacat, to Vigan, witnessed their entry into the Bagay establishment, heard a commotion and a scream, and then saw the group flee hastily, with one member holding a green folder and making incriminating statements.
During the trial, Dalacat’s original counsel withdrew. At a hearing on June 13, 2001, with his new counsel absent, Dalacat, upon questioning by the trial judge, unexpectedly changed his plea to guilty. The court immediately rendered a judgment of conviction, sentencing him to death. Both the defense, in its appellant’s brief, and the Office of the Solicitor General, in its manifestation, subsequently argued that the plea of guilty was improvidently made and requested a remand of the case for further proceedings.
ISSUE
Whether the trial court erred in accepting accused-appellant’s plea of guilty and immediately rendering judgment without conducting a searching inquiry to ensure the plea was made voluntarily and with full comprehension of its consequences.
RULING
Yes. The Supreme Court set aside the decision and remanded the case for further proceedings. The Court emphasized the stringent requirements for accepting a plea of guilt, especially in capital offenses. A plea of guilt must be based on a free and informed judgment. The trial court has a duty to conduct a “searching inquiry” into the voluntariness and full comprehension of the accused, ensuring he understands the nature of the charge, the meaning and consequences of his plea, and the precise penalty that could be imposed.
The trial court failed in this duty. The record showed only a brief, cursory questioning of Dalacat about his change of plea. The court did not explain the elements of the complex crime of robbery with homicide, the qualifying and aggravating circumstances, or the mandatory penalty of death. It did not inquire into Dalacat’s age, educational attainment, or state of mind to gauge his understanding. Furthermore, the plea was entered without the presence of his newly-appointed counsel, violating his right to assistance of counsel. Given these deficiencies, the plea could not be considered as knowingly and intelligently made. The proper course was to receive evidence to determine guilt with moral certainty, thus necessitating a remand for the continuation of the trial.