G.R. No. L-33303 November 21, 1980
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RODOLFO GONZALES alias Rudy Crazy, ROMEO LACHICA alias Jimmy alias Ringo, FRANCISCO MENSORADO, ROGELIO ESPINOSA Alias Tigas, ANDRES NARAG, GERARDO CALUBAG alias Ranger and HARDELITO REPIL.

FACTS

Seven accused, all convicts serving sentences at the Davao Penal Colony, were charged with double murder and double frustrated murder for killing two fellow prisoners and assaulting two others on June 22, 1969. The information alleged treachery, evident premeditation, and abuse of superiority. During arraignment on November 7, 1969, all seven accused, assisted by counsel de oficio, pleaded guilty. The trial court meticulously questioned each accused individually to confirm their understanding of the charges and the consequences of their plea. Satisfied with their voluntary and informed pleas, the trial court rendered judgment on the same day, convicting them.
The trial court found the seven guilty of double murder and double frustrated murder. For each murder, it imposed the death penalty, presumably qualifying the crimes with treachery. It considered the plea of guilty as a mitigating circumstance, offsetting the aggravating circumstance of abuse of superiority, but overlooked evident premeditation. For the frustrated murders, it imposed indeterminate penalties. The case was elevated to the Supreme Court for automatic review of the death sentences.

ISSUE

The primary issue for review was the propriety of imposing the death penalty based solely on the accused’s pleas of guilty without requiring the prosecution to present evidence, and the correct appreciation of aggravating circumstances, particularly quasi-recidivism.

RULING

The Supreme Court affirmed the convictions but commuted the death penalties to reclusion perpetua due to the lack of the requisite votes for imposition. The Court held that the trial court did not abuse its discretion in dispensing with the reception of evidence after the pleas of guilty. It emphasized that when an accused pleads guilty freely and voluntarily with full understanding of the nature of the charge and its consequences, such a plea is sufficient to sustain a conviction. The duty to receive further evidence is discretionary, not mandatory, and is necessary only when there is doubt regarding the voluntariness or comprehension of the plea. Here, the trial court’s careful interrogation and the existence of sworn extrajudicial confessions in the record negated any such doubt.
On the legal circumstances, the Court ruled that treachery absorbed the aggravating circumstance of abuse of superiority. Crucially, it found the special aggravating circumstance of quasi-recidivism under Article 160 of the Revised Penal Code to be sufficiently alleged and proven. The information specified that the accused were convicts serving sentences when they committed the crimes within the penal colony. This allegation, coupled with judicial notice of their status, justified the original imposition of the supreme penalty. However, the Court ultimately commuted the sentences to two reclusion perpetuas per accused for the murders, subject to the rules on the service of multiple penalties, citing the lack of necessary votes and the prolonged incarceration of the accused. The civil indemnity was affirmed.