GR L 2647; (February, 1906) (Digest)
G.R. No. L-2647
FACTS:
The defendant-appellant, Felix Paquit, was charged with the crime of illegal detention. Upon arraignment on April 11, 1905, he pleaded guilty. However, on April 14, 1905, before the final judgment was rendered, he filed an affidavit stating that he had misunderstood the complaint and its effects when he entered his plea. He clarified that while he was present during the detention, he was himself a prisoner at the time and did not voluntarily participate in the crime, and thus believed he was not guilty. This filing was effectively a request to withdraw his plea of guilty and substitute it with a plea of not guilty. The trial court, in a judgment dated April 14, 1905 (rendered after the affidavit was filed), sentenced him to six years and one day of prision mayor based solely on his original plea of guilty, without taking any evidence. The court denied his request to change his plea.
ISSUE:
Whether the trial court committed a reversible error in denying the defendant’s request, made before final judgment, to withdraw his plea of guilty and substitute it with a plea of not guilty.
RULING:
Yes. The Supreme Court set aside the judgment of the trial court and ordered a new trial. The Court held that under Section 25 of General Orders No. 58, the trial court had the discretionary power to allow a change of plea from guilty to not guilty at any time before judgment. Since the defendant’s request was made before judgment and was based on a claim of having misunderstood the complaint and his alleged innocence, and no good or weighty reason appeared on record to deny it, the trial court abused its discretion in refusing the request. Judicial discretion should be exercised to facilitate, not obstruct, the defense of the accused in the interest of justice. The denial deprived the defendant of the opportunity to present a defense. The case was remanded to the lower court to allow the defendant to plead not guilty, for the presentation of evidence, and for the amendment of the complaint to specify the duration of the illegal detention, as this determines the penalty. Costs were declared de oficio.