GR 141129; (December, 2001) (Digest)
G.R. Nos. 141129-33; December 14, 2001
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROLAND MOLINA y JOVERE, accused-appellant.
FACTS
Accused-appellant Roland Molina was charged with one count of attempted rape and four counts of incestuous rape committed against his 16-year-old daughter, Brenda Molina. After initially pleading not guilty to all charges, Molina, during trial, manifested his desire to change his plea to guilty for all five crimes, stating he was “bothered by his conscience.” The trial court re-arraigned him after noting that the consequences were explained by his counsel and the prosecutor. The prosecution nonetheless presented evidence, after which the trial court convicted Molina. He was sentenced to an indeterminate penalty for attempted rape and four death penalties for the consummated rapes. The case was elevated to the Supreme Court for automatic review.
ISSUE
Whether the trial court committed reversible error in accepting accused-appellant’s plea of guilty without conducting a searching inquiry into its voluntariness and comprehension, thereby rendering the plea improvident.
RULING
Yes. The Supreme Court reversed the convictions and remanded the cases for further proceedings. The Court held that the trial court failed to comply with the mandatory duty under Section 3, Rule 116 of the Rules of Court to conduct a “searching inquiry” when an accused pleads guilty to a capital offense. A searching inquiry requires the judge to ensure the accused fully comprehends the meaning and consequences of his plea, the nature of the charges, and the precise penalty. The record was bereft of any showing that the trial judge personally examined Molina to ascertain his voluntariness and understanding. The mere notation that counsel and prosecutor explained the consequences is insufficient; the judge must undertake a direct, painstaking interrogation. This procedural lapse rendered the plea of guilty improvident. Consequently, the conviction based on an invalid plea cannot stand. The Court ordered a new arraignment and further trial to ensure due process.