G.R. No. L-30820 July 31, 1970
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RODRIGO ENGLATERA, defendant-appellant.

FACTS

Rodrigo Englatera was charged with murder in the Circuit Criminal Court for hacking Carmelita Ardiente to death with a bolo on March 6, 1969. Upon arraignment on May 20, 1969, he pleaded not guilty. However, on July 8, 1969, his counsel moved to withdraw the not guilty plea and substitute it with a plea of guilty after re-arraignment. The court granted the motion, and upon being re-arraigned, Englatera pleaded guilty as charged. The defense argued that only the mitigating circumstance of plea of guilty should be considered, and that the aggravating circumstances alleged in the information (superior strength, disregard of sex, and cruelty) should be disregarded. The prosecution objected, contending that by pleading guilty, Englatera admitted all allegations, including the aggravating circumstances. The trial court, after requiring memoranda, held that even if the three aggravating circumstances were disregarded, the information contained two qualifying circumstances (treachery and evident premeditation). It ruled that only one is necessary to qualify the killing as murder, and the other should be treated as a generic aggravating circumstance. Considering the plea of guilty as a mitigating circumstance and five aggravating circumstances (the three alleged plus recidivism and the extra qualifying circumstance treated as generic), the court sentenced Englatera to death. Counsel de oficio filed a petition for new trial, arguing that Englatera’s fundamental rights were violated as the trial court did not adequately inform him of the nature of the charge and the consequences of his guilty plea before accepting it.

ISSUE

Whether the trial court committed a reversible error by accepting the appellant’s plea of guilty without first conducting a searching inquiry to ensure that the plea was made voluntarily, with full understanding of its nature and consequences, especially in a capital offense.

RULING

Yes. The Supreme Court set aside the decision and remanded the case for further proceedings. The Court found the motion for new trial justified. Citing its previous rulings in People vs. Apduhan and People vs. Solacito, the Court held that in cases where the accused pleads guilty to a capital offense, the trial court must conduct a searching inquiry to ensure the plea is voluntary and made with full comprehension of the charge and its consequences. The record showed that after the motion to withdraw the not guilty plea was granted, the appellant was simply re-arraigned and pleaded guilty. The trial judge did not propound any questions to the appellant, gave no admonition, and did not establish the voluntariness of the plea or the appellant’s awareness that pleading guilty to murder with multiple aggravating circumstances could lead to a death sentence. This failure violated the appellant’s fundamental rights and due process. The case was remanded specifically for the appellant to be arraigned once more, with the assistance of counsel, and with full information regarding the nature and gravity of the offense and the penalty that might be imposed.