G.R. No. L-38625 October 23, 1981
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EDUARDO ROSALES, LUIS ROSALES and SANTOS CARCER, defendants-appellants.

FACTS

The case involves the automatic review of death sentences imposed on appellants for the murder of fellow inmate Renato Martin inside the New Bilibid Prison on November 16, 1970. The information alleged that Eduardo Rosales and Guillermo Natural, as leaders of the Bicol Region Masbate Gang (BRM), ordered the killing, which was carried out by Luis Rosales and Santos Carcer, who were armed with improvised weapons. The crime was qualified by treachery. On December 24, 1971, Luis Rosales and Santos Carcer, assisted by counsel, pleaded guilty. The trial court, after a brief colloquy where the accused stated they were ready to die, immediately sentenced them to death without receiving evidence. Eduardo Rosales pleaded not guilty. After trial, where Natural testified as a state witness, he was also convicted as the mastermind and sentenced to death on March 24, 1973.

ISSUE

The primary issue is whether the trial court committed reversible error in: (1) imposing the death penalty on Luis Rosales and Santos Carcer based solely on their plea of guilty without conducting a searching inquiry into the voluntariness and consequences of the plea and without requiring evidence; and (2) convicting Eduardo Rosales based on the evidence presented.

RULING

The Supreme Court affirmed all death sentences. For Luis Rosales and Santos Carcer, the Court held that while the trial court’s inquiry into their plea was “perfunctory,” the error was not fatal. The Court reasoned that the appellants, being recidivists and habitual delinquents already serving final sentences, were fully aware of the gravity of their plea and its consequences. Their explicit statement in court that they were “ready to die in the electric chair” and had contemplated pleading guilty for a year demonstrated a conscious and deliberate choice. Furthermore, the detailed information, which they admitted in their plea, clearly alleged all elements of murder qualified by treachery, committed by inmates. Under Article 160 of the Revised Penal Code, which prescribes the death penalty for a new felony committed by a person already serving a final sentence, the penalty was mandatory. Thus, even if evidence had been taken, the outcome would have been the same, rendering any procedural lapse harmless.
Regarding Eduardo Rosales, the Court found his conviction supported by overwhelming evidence. The testimony of state witness Guillermo Natural, who detailed Rosales’s role as the ordering party, was credible and corroborated. The Court rejected Rosales’s claim that his extrajudicial confession was coerced, noting it contained details only he could know and was consistent with other voluntary statements. His leadership in the BRM gang and his instigation of the murder were firmly established. Consequently, as a person already serving a final sentence who committed a new capital offense, the imposition of the death penalty under Article 160 was also correct as to him.