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

FACTS

Accused-appellant Brendo Pagal was charged with murder. During arraignment before the Regional Trial Court (RTC), he entered a plea of guilty. The RTC, in compliance with procedural rules, set four hearing dates specifically for the prosecution to present evidence to prove his guilt and the precise degree of culpability, despite the plea. On all scheduled hearing dates, the prosecution failed to present any witnesses. The defense also opted not to present evidence. Both parties subsequently moved to submit the case for decision. The RTC then rendered a judgment convicting Pagal of murder based solely on his plea of guilt.
On appeal, the Court of Appeals (CA) found that the RTC failed to conduct the mandatory searching inquiry into the voluntariness and comprehension of Pagal’s guilty plea, rendering it improvident. The CA set aside the conviction and ordered the case remanded to the trial court for further proceedings. Unsatisfied, Pagal appealed to the Supreme Court, seeking a complete acquittal instead of a remand.

ISSUE

Whether the accused-appellant is entitled to an acquittal, rather than a remand of the case, after his conviction based on an improvident plea of guilty was set aside, given the prosecution’s failure to present evidence when given the opportunity.

RULING

Yes. The Supreme Court, through the ponencia of Justice Gesmundo, granted the appeal and acquitted Pagal. Chief Justice Peralta, in his concurring opinion, articulated the legal logic for this disposition. He emphasized that under Section 3, Rule 116 of the Rules of Court, when an accused pleads guilty to a capital offense, the court has a three-fold duty: (1) conduct a searching inquiry into the plea; (2) require the prosecution to prove guilt and the precise degree of culpability; and (3) allow the accused to present evidence. Critically, the prosecution’s burden to prove guilt beyond reasonable doubt remains absolute and is never discharged by a guilty plea alone, whether improvident or not.
Here, the RTC fulfilled its second duty by setting multiple hearings for the prosecution to present evidence. The prosecution’s unexplained failure to present any evidence during these opportunities meant it did not meet its indispensable burden of proof. Consequently, since the prosecution had already been given—and wasted—its chance to prove its case, a remand for the purpose of allowing it to present evidence would be unjust and contrary to procedure. It would effectively give the prosecution a second bite at the apple to the prejudice of the accused, who enjoys the constitutional presumption of innocence. Therefore, the proper remedy was acquittal, not remand. This case establishes an exception to the general rule of remanding cases with improvident pleas, applying when the prosecution fails to present evidence after being duly required and afforded the opportunity to do so.