GR 119073; (March, 1996) (Digest)
G.R. No. 119073 March 13, 1996
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ALBERTO DIAZ, accused-appellant.
FACTS
Accused-appellant Alberto Diaz was charged with the rape of his 14-year-old daughter. Upon arraignment, assisted by a Public Attorney’s Office lawyer, he pleaded guilty. The trial court, prior to accepting the plea, conducted an inquiry by placing Diaz on the witness stand. Diaz testified that he understood the charge, admitted to raping his daughter twice, and acknowledged that his plea was voluntary and that it could result in the death penalty. He confirmed he was in full control of his senses.
Satisfied with this inquiry into the voluntariness and comprehension of his plea, the trial court proceeded to render a decision convicting Diaz of rape and sentencing him to death based solely on his judicial confession. The case was elevated to the Supreme Court on automatic review. Diaz, through counsel, argued that the trial court erred in not requiring the prosecution to present evidence of his guilt and the precise degree of his culpability after his plea of guilty.
ISSUE
Did the trial court commit a reversible error by convicting the accused based solely on his plea of guilty to a capital offense without requiring the prosecution to present evidence?
RULING
Yes. The Supreme Court annulled and set aside the decision and remanded the case for proper proceedings. The Court emphasized that Section 3, Rule 116 of the Rules of Criminal Procedure mandates a strict three-fold procedure when an accused pleads guilty to a capital offense. First, the court must conduct a searching inquiry into the voluntariness and full comprehension of the plea’s consequences. Second, it must require the prosecution to present evidence to prove the accused’s guilt and the precise degree of culpability. Third, it must ask the accused if he desires to present evidence in his behalf.
In this case, the trial court only complied with the first requirement. Its inquiry, while establishing the plea’s voluntariness, was insufficient. Notably, the accused even revealed he was unaware his counsel could defend him if he chose to go to trial. Crucially, the court completely omitted the second mandatory step. It did not require the prosecution to present any testimonial or documentary evidence to establish the details of the crime and prove guilt beyond reasonable doubt. Conviction in capital offenses can no longer rest solely on a plea of guilt. The rule requires supporting evidence to minimize the risk of erroneous conviction, a fundamental value in the criminal justice system. The trial court’s failure to observe this procedure was a fatal error.