GR 117485; (April, 1996) (Digest)
G.R. Nos. 117485-86 April 22, 1996
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MELCHOR ESTOMACA y GARQUE, accused-appellant.
FACTS
Accused-appellant Melchor Estomaca, an illiterate laborer, was charged with five counts of rape against his 15-year-old daughter, Melita Estomaca. During his arraignment on June 14, 1994, assisted by a government counsel de oficio, the records were inconsistent regarding his pleas. The trial court’s decision stated he pleaded guilty to two cases (Criminal Case Nos. 43568 for an act in December 1993 and 43571 for an act on March 6, 1994) and not guilty to the other three. The prosecution presented evidence, wherein Melita testified to the rapes. The trial court, applying Republic Act No. 7659, sentenced Estomaca to reclusion perpetua for the December 1993 rape and the death penalty for the March 1994 rape.
ISSUE
Whether the trial court validly conducted the arraignment and accepted the accused’s plea of guilty to the capital offenses.
RULING
No. The Supreme Court set aside the conviction and remanded the cases. The legal logic is anchored on the mandatory procedure under Section 3, Rule 116 of the 1985 Rules on Criminal Procedure for a plea of guilty to a capital offense. The Court found the arraignment void due to the trial court’s failure to ensure the plea was entered intelligently and with full comprehension of its consequences. The transcript revealed the judge merely asked if the accused understood the charges and if he was pleading guilty, without conducting a searching inquiry into the voluntariness and full implications of the plea. Furthermore, the defense counsel’s participation was passive, failing to ensure adequate protection for the illiterate accused. Since a valid arraignment is a jurisdictional prerequisite, especially in capital cases where the penalty is irrevocable, its invalidity nullifies the subsequent proceedings and judgment. The Court emphasized that while it will impose the death penalty when warranted, it cannot do so when basic procedural rights, particularly of the poor and ignorant, are violated. This case was deemed on all fours with the precedent of People vs. Alicando, warranting the same disposition of remand for proper arraignment and trial.