G.R. No. L-15515. April 29, 1961. THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROGER PERETE Y MANLAPAS, ET AL., accused. ROGER PERETE Y MANLAPAS, accused-appellant.
FACTS

Roger Perete and Victorio Sajorda, inmates at the New Bilibid Prisons, were charged with murder for killing a fellow prisoner, Receval Langlangan, on March 25, 1959. The information alleged they conspired, armed with sharp instruments, and attacked the victim with treachery and evident premeditation, inflicting multiple stab wounds causing instantaneous death. It further alleged both were quasi-recidivists, having committed the crime while serving sentences from final convictions. Upon arraignment on June 2, 1959, Perete, assisted by counsel de oficio, pleaded guilty. His co-accused Sajorda pleaded not guilty. On the same day, the trial court rendered judgment against Perete, finding him guilty of murder qualified by treachery, appreciating the aggravating circumstances of evident premeditation and quasi-recidivism under Article 160 of the Revised Penal Code, and imposing the death penalty.
The case was elevated to the Supreme Court on automatic review. Appellant, through counsel de oficio, assigned errors, contending the trial court should have taken evidence despite the guilty plea to ascertain the crime’s nature and the presence of aggravating circumstances, arguing the crime was only homicide and that his plea and voluntary surrender should be mitigating.

ISSUE

Whether the trial court erred in convicting appellant of murder and imposing the death penalty based solely on his plea of guilty without receiving further evidence, and in appreciating the aggravating circumstance of quasi-recidivism.

RULING

The Supreme Court affirmed the conviction and the imposition of the death penalty. The Court held that a plea of guilt, when formally entered at arraignment, is sufficient to sustain a conviction for a capital offense without further evidence, as it constitutes an admission of all material allegations in the information, including qualifying and aggravating circumstances. While receiving additional evidence is a better practice in serious cases, it rests within the trial court’s sound discretion, provided it is satisfied the plea was made with full knowledge of its consequences.
The record showed no abuse of discretion. Appellant was assisted by counsel de oficio during arraignment, and the information was read and a copy delivered to him and his counsel before he entered a plea the judge described as “spontaneously and voluntarily.” Neither appellant nor his counsel complained that the plea was improvident. The plea admitted the allegations of treachery, evident premeditation, and quasi-recidivism. Furthermore, the record contained overwhelming evidence, including appellant’s own affidavit and that of his co-accused detailing the silent, sudden attack, and an autopsy report showing about 41 stab wounds.
On quasi-recidivism, the Court found the information’s allegation sufficient, as it stated appellant committed the felony while serving a sentence from a final conviction. This special aggravating circumstance, under Article 160, raises the penalty for the new crime to its maximum period. Even conceding the mitigating circumstances of plea of guilt and voluntary surrender, they could not offset quasi-recidivism to reduce the penalty from death. The Court found no merit in the other assigned errors.