G.R. No. 241257, September 29, 2020
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. BRENDO P. PAGAL, ACCUSED-APPELLANT.

FACTS

Accused-appellant Brendo Pagal pleaded guilty to the capital offense of murder. The trial court, after conducting a searching inquiry into the voluntariness and comprehension of his plea, proceeded to render judgment based solely on the plea and the prosecution’s offer of evidence, without requiring the prosecution to actually present its witnesses. The prosecution failed to present any witnesses on four scheduled hearing dates. The trial court deemed the prosecution to have waived its right to present evidence and, based on the judicial affidavit and documentary evidence already submitted, convicted Pagal and sentenced him to reclusion perpetua.
On appeal, the ponencia affirmed the conviction. It held that the trial court fulfilled its three-fold duty following a guilty plea to a capital offense: conducting a searching inquiry, requiring the prosecution to prove guilt, and allowing the accused to present evidence. It found that the prosecution was given ample opportunity to present witnesses but failed, and thus the trial court correctly deemed the right waived and rendered judgment based on the evidence already on record.

ISSUE

Whether the trial court committed reversible error by rendering judgment of conviction without the prosecution having presented testimonial evidence, and whether the case should be remanded for further proceedings.

RULING

The dissenting opinion argues for remand. It contends that the trial court failed in its duty to ensure the prosecution proved guilt beyond reasonable doubt. The prosecution’s failure to present witnesses on multiple dates did not constitute a valid waiver of its duty to present evidence. A valid waiver must be knowing, intelligent, and voluntary, with persuasive evidence of an actual intent to relinquish the right. The court must indulge every reasonable presumption against waiver.
The dissent emphasizes that the duty to prove guilt is a positive obligation the court cannot relieve the prosecution of. Merely setting hearing dates is insufficient. When witnesses failed to appear, the trial prosecutor should have sought, and the trial judge should have obliged, coercive measures under the Rules of Court to compel attendance. The failure to employ such measures resulted in an abbreviated proceeding that deprived the court of a complete factual basis for judgment, constituting a miscarriage of justice. Therefore, the improvident handling of the post-plea proceedings, where the defense played practically no role and the prosecution presented no live testimony, justifies remanding the case to the trial court to allow the prosecution to present its evidence and the accused to present his defense, ensuring due process is fully observed.