G.R. No. 140208 . March 12, 2002.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ELPIDIO PASTOR, accused-appellant.

FACTS

Accused-appellant Elpidio Pastor was charged with incestuous rape of his 13-year-old daughter, Maria Niña R. Pastor, which resulted in her pregnancy. Initially pleading not guilty, he later changed his plea to guilty during the hearing. The Regional Trial Court conducted a re-arraignment, read the information in the Visayan dialect, and propounded clarificatory questions. The prosecution presented evidence, including the victim’s testimony detailing the rape and its consequences. The trial court convicted Pastor and imposed the death penalty, albeit with a recommendation for executive clemency to reclusion perpetua due to his remorseful attitude.
On appeal, Pastor contended that the trial court failed to conduct the mandatory “searching inquiry” into the voluntariness and full comprehension of his guilty plea, as required for capital offenses under Section 3, Rule 116 of the Revised Rules of Criminal Procedure and jurisprudence. He argued the court’s questions were limited to his personal circumstances, insufficient to ensure he understood the plea’s grave consequences.

ISSUE

Whether the trial court committed a reversible error by not conducting a proper searching inquiry into the voluntariness and comprehension of accused-appellant’s plea of guilty to a capital offense.

RULING

Yes. The Supreme Court set aside the judgment and remanded the case for further proceedings. The Court emphasized that a plea of guilty to a capital offense demands the highest degree of scrutiny. The trial court must conduct a searching inquiry to ensure the accused fully understands the nature of the charge, the meaning of a guilty plea, and its inevitable consequence of death. This inquiry must be more than perfunctory; it should involve questions not only about the accused’s personal profile but, more critically, about his comprehension of the charge, the precise acts he is admitting, and the penalty prescribed by law.
In this case, the trial court’s questions were primarily confined to Pastor’s family background, age, and education. It failed to delve into whether he grasped the essential elements of incestuous rape, the allegations in the information, or the certainty of the death penalty. This omission constituted a fatal flaw, as it left a doubt regarding whether the plea was truly intelligent and voluntary. The Court also noted the deficient performance of the defense counsel, who inadequately safeguarded the accused’s rights. Consequently, the fundamental requirements of due process were not satisfied, necessitating a remand for a proper re-arraignment and trial to ascertain the accused’s guilt with certainty.