GR L 2647; (March, 1950) (Digest)
G.R. No. L-2647; March 30, 1950
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DIONISIO SERRANO Y SANDOVAL, defendant-appellant.
FACTS
Appellant Dionisio Serrano was charged with serious physical injuries for allegedly inflicting wounds on Francisco Augusto that “will require medical attendance for more than thirty but less than ninety days” and would prevent work for the same period. The information was filed one day after the incident. Appellant, without counsel, initially pleaded guilty. He later moved to withdraw his plea, claiming he believed the offended party would pardon him. The trial court denied his motion and, based on his guilty plea, convicted him of serious physical injuries and sentenced him to six months of arresto mayor. After judgment, appellant filed a motion to reopen the case, seeking to substitute his plea to guilty of the lesser offense of slight physical injuries, supported by an affidavit from the offended party stating the injuries healed in about nine days without incapacitation for work. The trial court denied this motion.
ISSUE
Whether the trial court abused its discretion in denying the appellant’s motion to withdraw his plea of guilty and to reopen the case for the purpose of substituting a plea to a lesser offense.
RULING
Yes. The Supreme Court set aside the judgment and remanded the case for new arraignment and trial. The Court held that while the withdrawal of a guilty plea is discretionary, the trial court clearly abused its discretion under the circumstances. The gravity of the offense charged depended on a future event—the duration of healing and incapacity—which was still uncertain at the time of the arraignment. The plea of guilty admitted the material facts but not the conjectural allegations about the future period of incapacity. The mistake was committed in good faith by the unaided accused, the fiscal, and the court. When it became evident through the offended party’s affidavit that the injuries were slight (healing in nine days), it was an injustice to convict the accused of a graver offense. The trial court’s refusal to reopen the case and allow correction of this mistake, despite an offer to prove the lesser offense with the offended party’s testimony and without rebuttal from the prosecution, constituted a clear abuse of discretion.
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