G.R. No. 130411 -14. October 13, 1999.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RODRIGO BELLO, accused-appellant.

FACTS

Accused-appellant Rodrigo Bello was charged with four counts of rape committed against his legitimate daughter, Jenalyn A. Bello, a minor, on August 13, 14, 19, and 24, 1995, in Tacloban City. The informations alleged that the rapes were committed by means of force and intimidation, with the aggravating circumstance of relationship. At arraignment, he pleaded not guilty. The prosecution presented the victim’s testimony detailing the incidents: on August 13, 1995, at 3 a.m., her drunken father woke her, ordered her to the kitchen, forced her to undress, and had carnal knowledge of her despite her pleas; on August 14, 1995, at 1 a.m., he repeated the act while her mother was away; on August 19, 1995, at 3 a.m., he raped her again in the kitchen; and on August 24, 1995, at 9 a.m., he raped her despite her menstruation and during her periodical exams. On April 16, 1996, during cross-examination, accused-appellant, through counsel, manifested his desire to withdraw his not guilty plea and substitute it with a guilty plea. The trial court allowed the change of plea after being convinced accused-appellant understood the consequences. The defense cross-examined the complainant and presented accused-appellant to prove mitigating circumstances. Later, accused-appellant moved to reinstate his not guilty plea, but the trial court denied this. On November 21, 1996, the trial court rendered judgment finding accused-appellant guilty of four counts of rape and sentenced him to death for each count, plus indemnity and damages.

ISSUE

Whether the trial court erred in convicting accused-appellant despite failing to observe the required procedure for cases where the accused pleads guilty to a capital offense, specifically in not conducting a proper searching inquiry into the voluntariness and comprehension of the plea.

RULING

The Supreme Court vacated the judgment of conviction and remanded the cases for proper arraignment and trial. The Court held that the trial court failed to comply with the mandatory procedure under Section 3, Rule 116 of the Revised Rules on Criminal Procedure for cases where the accused pleads guilty to a capital offense. This rule requires: (1) a searching inquiry into the voluntariness and full comprehension of the consequences of the plea; (2) requirement for the prosecution to present evidence to prove guilt and precise degree of culpability; and (3) allowing the accused to present evidence if desired. The record showed the trial court’s inquiry was insufficient, as it did not fully explain the consequences of the plea or ensure accused-appellant understood the charges and penalties. Notably, during his testimony, accused-appellant denied the rape charges, stating he pleaded guilty out of fear of being killed. This denial effectively vacated his guilty plea, and the trial court should have required a new plea of not guilty and proceeded to trial. The Court emphasized that in capital offenses, extra solicitude is required to ensure the plea is voluntary and comprehended, as the death penalty is irrevocable. Thus, the cases were remanded to the trial court for proper arraignment and trial, with instructions for priority and circumspect proceedings.