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, with the information alleging the injuries “will require medical attendance for a period of more than thirty but less than ninety days” and would prevent the victim from working for that period. The information was filed one day after the incident. Appellant, without counsel, pleaded guilty. Later, he moved to withdraw his plea, alleging he believed the victim would pardon him. The motion was denied, and he was convicted. Subsequently, he filed a motion to reopen the case, seeking to substitute his plea to one of guilty to the lesser offense of slight physical injuries, supported by the victim’s affidavit stating the injuries healed in about nine days without incapacitation. The trial court denied this motion.

ISSUE

Whether the trial court gravely abused its discretion in denying the appellant’s motion to withdraw his plea of guilty.

RULING

Yes. The Supreme Court set aside the judgment and remanded the case for new arraignment and trial. While the withdrawal of a plea of guilty is discretionary, the trial court committed a clear abuse of discretion under the circumstances. The gravity of the offense charged depended on a future event—the duration of the victim’s incapacity—which was still uncertain at the time of the arraignment. The plea of guilty did not constitute an admission of such conjectural allegations. A serious injustice occurred as the appellant, unaided by counsel, was convicted of a graver offense than what the evidence (the victim’s affidavit) indicated he actually committed. The court had a duty to require evidence to dispel the uncertainty before imposing penalty. The refusal to reopen the case after the true facts were presented was unjustified.

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