G.R. No. L-32752-3. January 31, 1977.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MIGUEL BALUYOT y DULAY, PABLO PINCA y NARCA and ANTONIO BALINJARI y NAVAL, alias TONY BALUYOT, defendants-appellants.

FACTS

The accused were charged with Robbery with Homicide for robbing and killing a taxi driver on August 6, 1970, in Malolos, Bulacan. After initially pleading not guilty at arraignment, their trial commenced with the prosecution presenting a medico-legal officer and police witnesses over two hearing dates. At the third hearing, a newly appointed counsel de oficio, after a brief conference, manifested the accused’s desire to withdraw their not guilty plea and substitute it with a plea of guilty. The trial court, after a cursory confirmation from each accused, immediately dictated its decision convicting them and imposing the death penalty, considering the plea as a mitigating circumstance offset by three generic aggravating circumstances.

ISSUE

Whether the trial court committed a reversible error in accepting the accused’s change of plea to guilty and rendering judgment without conducting a searching inquiry into the voluntariness and comprehension of the plea and without requiring further evidence.

RULING

Yes. The Supreme Court set aside the conviction and remanded the case for further proceedings. The legal logic is anchored on the mandatory duty of trial courts in capital offenses. A plea of guilty, especially when it results in a capital sentence, must be scrutinized with utmost care to ensure it is entered voluntarily, intelligently, and with full understanding of its consequences. The court must conduct a “searching inquiry” into the accused’s comprehension and the factual basis of the plea. Furthermore, under Section 3, Rule 116 of the Rules of Court, when a plea of guilty is entered in a capital offense, the court must still require the prosecution to present evidence to establish the guilt and precise degree of culpability of the accused. This procedural safeguard is designed to prevent improvident pleas and to ensure no reasonable doubt remains. Here, the trial court failed on both counts. It asked only perfunctory questions to affirm the change of plea and immediately proceeded to sentencing without receiving further evidence from the prosecution. This omission deprived the court of a basis to properly appreciate the presence of aggravating and mitigating circumstances and to verify the factual accuracy of the plea itself, constituting a grave denial of due process.