G.R. No. L-26868 July 29, 1971
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. REMEGIO ESTEBIA, defendant-appellant.

FACTS

The accused, Remegio Estebia, was charged with rape committed with the use of a deadly weapon and aggravated by the circumstances of recidivism and the crime being committed in an uninhabited place. Upon arraignment, with the assistance of counsel de oficio, the accused initially expressed his desire to plead guilty. The trial court, Judge Manuel R. Pamaran presiding, meticulously informed him of the gravity of the charge and the possibility of a death penalty, even granting a recess for mature deliberation. Upon resumption, the accused, through his counsel, affirmed his plea of guilty. The court then proceeded to conduct a searching inquiry into the voluntariness and comprehension of his plea.
During this inquiry, the accused made several statements that fundamentally contradicted an admission of guilt. He stated, “To be candid, sir, I would have not entered the plea of guilty,” and explained his plea was motivated by poverty and a prior criminal record, asserting, “I cannot fight this case as I am very poor.” Most crucially, he explicitly denied committing the crime: “To tell the truth also, sir, in this case when it happened it is not true that I raped her.” Despite these clear assertions of innocence, and after being reminded he could reconsider his plea and would be provided a lawyer for a fair trial, the accused made an ambiguous statement, “I submit myself to the discretion of the Court.” The trial court subsequently rendered a judgment of conviction based on the plea and sentenced him to death.

ISSUE

Whether the accused’s plea, given his subsequent categorical denials of culpability during the court’s searching inquiry, constitutes a valid plea of guilty upon which a conviction can be based.

RULING

No. The Supreme Court reversed the conviction and remanded the case for further proceedings. The legal logic centers on the constitutional presumption of innocence and the stringent requirements for a valid plea of guilty in capital offenses. A plea of guilty must be unconditional, made with full comprehension of its consequences, and must truly constitute an admission of all the elements of the crime. The Court emphasized that a trial judge has a duty to conduct a searching inquiry to ensure the plea is voluntary and intelligently made, especially where the penalty is death.
In this case, the accused’s responses during the inquiry utterly negated the essential element of an admission of guilt. His statements—that he did not rape the victim, that his plea was driven by poverty and fear due to a prior conviction, and his initial expression of a desire not to plead guilty—collectively demonstrated that his mind did not accord with his initial verbal plea. A plea mired in such confusion and contradiction cannot be considered as a categorical admission of guilt. The Court held that where the accused, after pleading guilty, makes statements essentially amounting to a defense or a denial of the crime, the plea becomes invalid. The trial court therefore erred in accepting the plea and rendering a conviction. The proper course was to set aside the plea, enter a plea of not guilty for the accused, and proceed to trial to determine his guilt based on evidence.