G.R. No. 77969 June 22, 1989
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. PATRICK DE LUNA, defendant-appellant.

FACTS

Patrick de Luna was charged with Murder for the death of Tricia. During his arraignment on December 23, 1986, while assisted by counsel, he entered a plea of guilty but with the repeated qualification, “hindi ko sinasadya” (I did not mean to do it). He explained he was drunk and had no motive to kill. The trial judge inquired if he understood the charge was a capital offense, to which de Luna affirmed but reiterated his qualification. When asked if the prosecution should present evidence, de Luna stated, “No more evidence. No more presentation of evidence. I accept my fault but I want the court to know that I have no motive to kill her.”
Based solely on this qualified plea and without requiring the prosecution to present evidence, the trial court rendered a decision on the same day, convicting de Luna of Murder and sentencing him to reclusion perpetua. The court appreciated his plea of guilty and his manifestation of lack of intention as mitigating circumstances. De Luna appealed, arguing his qualified plea was not a valid admission to Murder and that the trial court erred in not requiring evidence despite his waiver.

ISSUE

The main issues are: (1) Whether de Luna’s qualified plea constituted a valid plea of guilty to the crime of Murder; and (2) Assuming a valid plea, whether the trial court could dispense with the presentation of prosecution evidence based on the accused’s waiver.

RULING

The Supreme Court set aside the trial court’s decision and remanded the case for new arraignment and proceedings. On the first issue, the Court held that a plea of guilty must be unconditional; it admits all the material allegations in the information, including qualifying circumstances like treachery. De Luna’s persistent qualification that he did not intend the killing negated an absolute admission of guilt for Murder, as it effectively denied the deliberate intent and the qualifying circumstances alleged. His statements indicated a possible plea only to Homicide, not Murder, revealing a lack of full comprehension of the charge’s nature and consequences.
On the second issue, the Court ruled that in capital offenses like Murder, a plea of guilty mandates the trial court to: (1) conduct a searching inquiry into the voluntariness and comprehension of the plea; (2) require the prosecution to present evidence to prove guilt and the precise degree of culpability; and (3) allow the accused to present evidence if desired. This procedure is mandatory and cannot be waived by the accused. The trial court’s failure to require evidence, despite de Luna’s purported waiver, was a fatal error. The presentation of evidence is indispensable to ascertain the true circumstances of the crime and to remove any doubt regarding the accused’s understanding of his plea and the precise degree of his liability.