GR 150033; (November, 2004) (Digest)
G.R. No. 150033 November 12, 2004
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DANILO ESPIDOL y VILLANUEVA (Deceased), SAGRADO DALACAT y SANTOS, ALFREDO TOMAS y LIMOS (At-large), AND ARMANDO ANIASCO, accused. SAGRADO DALACAT y SANTOS, accused-appellant.
FACTS
Accused-appellant Sagrado Dalacat, along with others, was charged with Robbery in Band with Homicide for staging a hold-up at the Bagay family’s business establishment in Vigan, Ilocos Sur, on October 14, 1998. During the incident, Hipolito Bagay was shot and killed, and P1.2 million was taken. Appellant initially pleaded not guilty. During trial, the prosecution presented driver Virgilio Corpuz, who testified about transporting the group and witnessing their suspicious behavior before and after the crime, and Johanna Go, an employee who identified appellant as one of the armed perpetrators. After the prosecution rested, appellant, through a new counsel, moved to withdraw his plea and enter a plea of guilty, which the trial court granted.
ISSUE
Whether the trial court erred in accepting appellant’s change of plea from not guilty to guilty and in convicting him based on an improvident plea.
RULING
Yes. The Supreme Court set aside the conviction and remanded the case for further proceedings. The plea of guilty was improvidently made. The trial court failed to conduct the requisite “searching inquiry” to ensure appellant fully comprehended the consequences of his plea, especially given the gravity of the capital offense. The court merely asked perfunctory questions about his age and education, which was insufficient. Furthermore, the court did not require the prosecution to present evidence to substantiate the plea and ascertain the precise degree of his culpability, as mandated by jurisprudence for cases involving the death penalty. The duty to conduct a searching inquiry is especially critical when the accused seeks to change his plea after the prosecution has already presented its evidence, as it must be determined that the plea is based on a full realization of its meaning and not due to any improper influence or coercion. The failure to observe these stringent safeguards rendered the plea invalid. The case was remanded to allow appellant to re-plead and for the trial to proceed to determine his guilt with certainty.