GR 65376; (December, 1989) (Digest)
G.R. No. 65376 December 29, 1989
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MAURICIO PETALCORIN alias JUNIO BUDLAT and BERTOLDO ABAIS alias TOLDONG, defendants-appellants.
FACTS
On April 18, 1979, Joemarico Porcadilla and Bonifacio Paden were aboard the pumpboat LOU JR in Bohol seawaters when their vessel was intentionally bumped by another pumpboat piloted by Bertoldo Abais. Mauricio Petalcorin, a passenger on the attacking boat, fired at Paden, causing him to fall into the sea, and then shot Porcadilla in the arm. Following a struggle where an accomplice, Paul Sagarino, also assaulted Porcadilla, Petalcorin and Sagarino seized the LOU JR and its cargo, speeding away. Paden, who had been holding onto the boat, was dragged and later died from his wounds, while Porcadilla was eventually rescued.
The crime remained undiscovered until January 1983, when Abais was apprehended for unrelated burglaries. During investigation, he confessed to the piracy and led police to recover parts of the stolen pumpboat from an accomplice, Felix Estillore. Based on these revelations and Porcadilla’s testimony, an Information for Piracy under Presidential Decree No. 532 was filed against Petalcorin and Abais. Both accused initially pleaded guilty upon arraignment.
ISSUE
Whether the trial court correctly convicted the appellants of the crime of Piracy, and whether their pleas of guilty were improvidently made given the imposition of the death penalty.
RULING
Yes, the conviction is affirmed, but the penalty is modified. The Supreme Court held that the evidence overwhelmingly established the crime of Piracy. The elements of attacking and seizing a vessel upon the high seas through violence and intimidation for personal gain were proven through the detailed testimony of victim Porcadilla and the corroborative extrajudicial confession and acts of accused Abais. The Court found conspiracy, as the appellants acted in concert to overtake the vessel, employ armed violence, and dispose of the stolen property.
Regarding the plea, the Court ruled that while the trial court failed to conduct the requisite “searching inquiry” to ensure the voluntariness and full comprehension of a guilty plea in a capital case, this procedural lapse did not invalidate the conviction. Following precedent, when the trial court—despite the plea—still required the prosecution to present evidence, the conviction is properly based on that evidence, not the plea itself. Consequently, the plea’s improvidence only negates its value as a mitigating circumstance; it does not overturn a judgment grounded on sufficient proof. However, due to the constitutional prohibition on the death penalty at the time of the decision, the penalty was reduced to reclusion perpetua, and civil indemnity was increased to P30,000.00.