G.R. No. 144404 . September 24, 2001.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. LEODEGARIO BASCUGUIN Y AGQUIZ, accused-appellant.

FACTS

Accused-appellant Leodegario Bascuguin was charged with rape with homicide. At his arraignment on August 5, 1999, he appeared without counsel. The trial court appointed a counsel de officio, Atty. Macasaet. After a brief conference, the accused pleaded guilty to the capital offense. The trial court then asked a few questions to ascertain the voluntariness of his plea. Despite the guilty plea, the court proceeded to conduct a trial on the merits to determine the precise degree of culpability. The prosecution presented circumstantial evidence, including witness accounts placing the victim with the accused, the discovery of the victim’s body, and forensic analysis linking blood found on the accused’s belongings and a rope from his tricycle to the victim’s blood type. The accused presented no evidence. The trial court convicted him and imposed the death penalty.
On automatic review, the accused-appellant contended that his plea of guilt was improvident, that the trial court violated procedure by not inquiring if he desired to present evidence, and that the circumstantial evidence was insufficient. The Solicitor General joined in questioning the validity of the arraignment proceedings and recommended setting aside the conviction and remanding the case.

ISSUE

Whether the trial court’s acceptance of the accused-appellant’s plea of guilty, following an arraignment where he was assisted by a court-appointed counsel who conferred with him only briefly, was valid and accorded with due process.

RULING

No. The Supreme Court annulled the judgment of conviction and remanded the case for proper proceedings. The Court found the arraignment fatally defective, rendering the subsequent conviction void. The transcript revealed that counsel de officio conferred with the accused only momentarily before the arraignment. This limited consultation was grossly insufficient to satisfy the constitutional guarantee of competent and effective assistance of counsel. The right to counsel is not a mere formality; it requires that counsel explain the nature of the charge, the meaning of a guilty plea, and its consequences, especially in a capital case. The cursory nature of the consultation here deprived the accused of adequate guidance, casting serious doubt on the voluntariness and intelligence of his plea. While the trial court propounded questions, these could not cure the fundamental defect of inadequate counseling at the critical stage of arraignment. The Court emphasized that no matter how heinous the crime, an uncompromising adherence to due process is paramount. A conviction based on an invalid arraignment cannot stand. Thus, in the interest of substantial justice, a new arraignment with the effective assistance of counsel was mandated.