GR 241257 Delos Santos (Digest)
G.R. No. 241257 , September 29, 2020
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. BRENDO P. PAGAL, Accused-Appellant.
FACTS
Accused-appellant Brendo P. Pagal pleaded guilty to the capital offense of Murder before the Regional Trial Court (RTC). The trial court convicted him based solely on this plea. On appeal, the Court of Appeals (CA) remanded the case to the RTC, ordering it to conduct the searching inquiry into the voluntariness and comprehension of the plea as mandated by Rule 116, Section 3 of the Rules of Court. The ponente, however, proposes acquittal due to the prosecution’s failure to present evidence of guilt beyond reasonable doubt.
ISSUE
Whether the accused-appellant should be acquitted for lack of prosecution evidence, or whether the case should be remanded for a proper searching inquiry and reception of evidence following a plea of guilty to a capital offense.
RULING
The dissenting opinion votes to remand the case. The legal logic centers on strict adherence to constitutional due process and procedural rules governing pleas to capital offenses. Article III, Section 14 of the Constitution guarantees the accused the right to be informed of the nature of the accusation. Rule 116, Section 3 imposes a three-fold duty on the court when an accused pleads guilty to a capital offense: (1) conduct a searching inquiry into the voluntariness and full comprehension of the plea’s consequences; (2) require the prosecution to prove guilt and precise culpability; and (3) allow the accused to present evidence.
Jurisprudence, such as People v. Tizon, underscores that this searching inquiry is mandatory to ensure the plea is based on a free and informed judgment. The record in this case is deficient. Beyond translating the Information into the local dialect, nothing shows the RTC specifically ascertained the voluntariness of the plea or the accused’s complete understanding of its legal effects, especially the attendant penalty. Given irregularities noted in the preliminary investigation and the relationship between the accused and key witnesses, which may have influenced proceedings, a proper searching inquiry is essential to safeguard due process. An acquittal based solely on the prosecution’s evidentiary lapse, without first ensuring the plea itself was validly entered, would be improper. Therefore, the case must be returned to the trial court for re-arraignment in full compliance with Rule 116, Section 3, allowing the prosecution its opportunity to present evidence.