G.R. No. 126955 . October 28, 1999.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROMEO TIZON y INKING a.k.a. ROMY BONDAT/BUNGAL, accused-appellant.

FACTS

Accused-appellant Romeo Tizon y Inking was charged with Rape with Homicide for the rape and killing of an eight-year-old minor, Jonabel Antolin y Romaila, on or about August 21, 1996, in Manila. Upon arraignment on September 10, 1996, with the assistance of his counsel de oficio, he pleaded guilty to the indictment. The trial court, after receiving evidence to determine the degree of culpability, rendered a decision on October 30, 1996, finding him guilty beyond reasonable doubt and imposing the death penalty, along with an award of damages. The case was elevated to the Supreme Court for automatic review due to the death sentence.

ISSUE

Whether the trial court complied with the mandatory procedure under Sections 1 and 3, Rule 116 of the Rules of Court when the accused pleaded guilty to a capital offense, thereby ensuring the plea was made voluntarily and with full comprehension of its consequences.

RULING

No. The Supreme Court annulled and set aside the judgment of conviction and remanded the case to the trial court for further appropriate proceedings. The Court found that the trial court failed to conduct the required “searching inquiry” into the voluntariness and full comprehension of the accused’s plea of guilty to a capital offense. The only record of the arraignment was a brief order stating the information was read and the accused pleaded guilty, with no showing that the court ascertained the accused’s understanding of the charge, the meaning of his plea, or its consequences. This failure to adhere to the exacting standards of Rule 116 rendered the arraignment and subsequent plea invalid. Consequently, the judgment of conviction based on an invalid arraignment cannot stand.