G.R. No. 135053 . March 6, 2002.
PEOPLE OF THE PHILIPPINES, appellee, vs. BENJAMIN GALVEZ, appellant.

FACTS

Appellant Benjamin Galvez was charged with multiple rape of his 16-year-old daughter, Cristina. During arraignment, he initially pleaded not guilty. Subsequently, with new counsel, he changed his plea to guilty. The Regional Trial Court, after receiving prosecution evidence, convicted him of qualified rape and imposed the death penalty. The trial court, citing People v. Alicando, acknowledged the requirement to require the prosecution to prove guilt beyond reasonable doubt despite a guilty plea in a capital case. It based its conviction on the victim’s credible testimony and the appellant’s plea.

ISSUE

Whether the trial court committed reversible error in accepting appellant’s plea of guilt without conducting a proper “searching inquiry” as mandated for capital offenses.

RULING

Yes. The Supreme Court set aside the decision and remanded the case for re-arraignment. The Court emphasized that under Section 3, Rule 116 of the Rules of Court and established jurisprudence, a trial court must conduct a “searching inquiry” into the voluntariness and full comprehension of a guilty plea in a capital offense. This inquiry is mandatory to ensure the accused understands the nature of the charge, the meaning of a guilty plea, and its consequences, including the specific penalty. The trial court’s inquiry in this case was cursory and insufficient. It merely asked generic questions about the plea’s voluntariness and whether the accused understood the charge, without explaining the gravity of the offense, the qualifying circumstances, or the implication of the death penalty. The failure to conduct this rigorous inquiry renders the plea improvident. Consequently, the plea cannot stand, and the conviction based thereon is invalid. The case must be returned to the trial court for proper proceedings to safeguard the constitutional rights of the accused.