G.R. No. L-6102, March 11, 1911
THE UNITED STATES vs. RUFINO DINEROS

FACTS

Rufino Dineros was charged with violating the Election Law for falsely declaring under oath, during his voter registration in Sorsogon on October 2, 1909, that he was not delinquent in paying public taxes when he actually was. During his arraignment, Dineros stated (in Spanish) “que se considero culpable” (“that he considered himself guilty”). The trial court rendered a judgment dated March 3, 1910, sentencing him to pay a fine of ₱200 and costs, with subsidiary imprisonment in case of insolvency. However, the clerk’s minutes indicated the arraignment occurred on March 13, 1910. Dineros appealed, arguing discrepancies between the judgment date and the arraignment date in the minutes, and questioning whether his statement (“considered himself guilty”) constituted a valid plea of guilty.

ISSUE

1. Whether the discrepancy between the date on the judgment (March 3, 1910) and the date of arraignment in the clerk’s minutes (March 13, 1910) invalidates the judgment.
2. Whether the accused’s statement “que se considero culpable” (“that he considered himself guilty”) constitutes a valid plea of guilty.

RULING

The Supreme Court AFFIRMED the judgment of conviction.

1. On the date discrepancy: The Court held that any clerical error in dating the judgment (e.g., writing March 3 instead of March 13) was harmless and did not prejudice any substantial right of the accused. The judgment carries a presumption of regularity, and the discrepancy does not undermine the validity of the proceedings, especially since the appeal was duly allowed and no rights were affected.

2. On the validity of the plea: The Court ruled that the accused’s statement “que se considero culpable” was equivalent to a plea of guilty. The essence of a guilty plea is the accused’s clear, voluntary, and unconditional admission of guilt. The form of words used is not critical as long as the admission is definite. Thus, “I consider myself guilty” is substantively the same as “I am guilty” or “I plead guilty.”

The Court emphasized that the trial judge’s notation of a “guilty” plea was preferable, but the clerk’s minutes did not invalidate the plea. The conviction was upheld, and costs were imposed on the appellant.