GR L 112; (December, 1901) (Digest)
G.R. No. L-112, December 14, 1901
THE UNITED STATES, plaintiff-appellee, vs. BERNARDO PATALA, defendant-appellant.
FACTS:
The defendant, Bernardo Patala, was charged with a crime. Initially, he entered a plea of “guilty” in the Court of First Instance. However, the trial judge, acting under Section 31 of General Orders No. 58 (the procedural law then in force), proceeded to hold a trial and allowed the accused to testify in his own defense. The prosecution objected to this procedure, arguing that a plea of “guilty” should end the proceedings and render the defendant’s testimony irrelevant. During the trial, the prosecution presented no evidence to prove the commission of the crime, relying solely on the plea. The defendant testified that the deceased, a ship’s cook, attacked him without justificationfirst by slapping and kicking him over missing fish, then by pursuing him with a knife. The defendant claimed he wrested the knife away during the struggle and inflicted the fatal wound in self-defense. The trial court convicted the defendant, who appealed.
ISSUE:
Whether the trial court erred in conducting a trial and considering the testimony of the accused after he had pleaded “guilty.”
RULING:
No, the trial court did not err. The Supreme Court held that under American legal principles embodied in General Orders No. 58, a judge has the discretion to allow a plea of “guilty” to be withdrawn and order a trial on the merits. This is proper when there is reasonable doubt about the defendant’s guilt or when the defendant, by offering testimony, effectively withdraws the plea. The Court noted that the concepts of “guilty” and “not guilty” were alien to Spanish law and that local dialects might not convey the full legal implication of a “guilty” plea, making judicial discretion crucial.
On the merits, the Court found the defendant’s testimony credible and established a case of complete self-defense under Article 8(4) of the Penal Code. The deceased’s unprovoked and violent attack with a deadly weapon placed the defendant in imminent danger of death, justifying his act of repelling the aggression. Since the prosecution presented no contrary evidence, the defendant’s criminal liability was negated.
The judgment of conviction was REVERSED. The defendant was ACQUITTED on the ground of self-defense, with costs de oficio.