G.R. No. 241257, September 29, 2020
People of the Philippines, Plaintiff-Appellee, vs. Brendo P. Pagal a.k.a. “Dindo,” Accused-Appellant.

FACTS

The accused-appellant, Brendo P. Pagal, pleaded guilty to the capital offense of Murder. The ponencia (majority opinion) concluded that the trial court failed to comply with the mandatory three-tiered duties under Section 3, Rule 116 of the 2000 Revised Rules of Criminal Procedure when an accused pleads guilty to a capital offense. These duties are: conducting a searching inquiry into the voluntariness and comprehension of the plea; requiring the prosecution to prove guilt and the precise degree of culpability; and inquiring if the accused wishes to present evidence. The ponencia found the plea improvident.
Notwithstanding this finding, the ponencia acquitted the appellant. It ruled that since the prosecution was given its day in court but failed to present evidence to prove the appellant’s guilt beyond reasonable doubt, acquittal was the proper remedy. The prosecution did not present its evidence following the guilty plea.

ISSUE

Whether the accused-appellant should be acquitted, or whether the case should be remanded to the trial court for re-arraignment and a new trial, given the trial court’s failure to comply with the mandatory procedure for a plea of guilt to a capital offense, resulting in an improvident plea.

RULING

Justice Gaerlan, in his dissenting opinion, disagreed with the acquittal. He agreed that the trial court failed in its duties, rendering the plea of guilty improvident. However, he argued that an improvident plea does not automatically warrant acquittal. The correct remedy, according to established jurisprudence, is to remand the case to the trial court for proper re-arraignment and a new trial.
The dissent emphasized that a conviction based on an improvident plea is set aside only if the plea is the sole basis for the judgment. If the trial court had relied on sufficient evidence, the conviction could stand. Here, the prosecution did not present evidence because the trial court neglected its duty to require it. This procedural failure by the court should not inure to the benefit of the accused by resulting in an acquittal, as it would deprive the State and the victim’s family of due process. The prosecution must be given a full opportunity to present its evidence to prove guilt beyond reasonable doubt. Justice Gaerlan voted to dismiss the appeal, which would affirm the conviction but on the ground that the case should be remanded for re-arraignment and a complete trial.