G.R. Nos. L-30464-5 November 13, 1975
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ALBERTO DOMINGO y NATO alias “BOY ARRANQUE”, ERNESTO MANGSAL y JIMENEZ alias “ERNING MATON”, EDUARDO VITUG y PUNILAS alias “BOY LUGA” and FRANCISCO AGNER y REDRINDO alias “FRANCING”, defendants, ALBERTO DOMINGO y NATO alias “BOY ARRANQUE” and FRANCISCO AGNER y REDRINDO alias “FRANCING”, defendants-appellants.

FACTS

Accused Francisco Agner, along with Alberto Domingo, Ernesto Mangsal, and Eduardo Vitug, were charged with Robbery with Homicide for a crime committed on February 24, 1969. Upon arraignment on March 8, 1969, Agner, assisted by counsel de oficio, pleaded guilty. The trial court accepted the plea and, after a joint hearing with his co-accused, sentenced Agner and Domingo to death on March 18, 1969. The penalty was based on the numerical superiority of aggravating circumstances over mitigating circumstances, including Agner’s plea of guilty and voluntary surrender. The case was automatically elevated to the Supreme Court for review due to the death penalty imposed.
Agner subsequently filed a Motion for New Trial on August 18, 1975, contending that his plea of guilty was improvidently entered and accepted. He argued the trial court failed to observe the required standard of care in ensuring he fully understood the nature and consequences of his plea to a capital offense. This motion followed a prior successful motion by his co-accused, Alberto Domingo, who was granted a new trial by the Supreme Court on January 31, 1974, on identical grounds.

ISSUE

Whether the trial court committed reversible error in accepting accused-appellant Francisco Agner’s plea of guilty without exercising the requisite solicitous care, thereby warranting a new trial.

RULING

The Supreme Court GRANTED the motion and ordered a new trial. The legal logic centers on the constitutional and jurisprudential mandate for trial courts to exercise extreme caution before accepting a plea of guilty in capital offenses. The Court emphasized that the record must affirmatively show the judge conducted a searching inquiry to ensure the accused comprehends the charge, the allegations in the information, and the full implications of a guilty plea, including its severity.
The Court found Agner’s situation even more deficient than that of his co-accused Domingo. The transcript of Agner’s arraignment was utterly barren, showing only his manifestation to plead guilty and the court’s order deferring sentencing. There was a “patent and total absence” of any dialogue demonstrating the judge ascertained Agner’s understanding. This failure violated the injunction established in People vs. Apduhan and reiterated in People vs. Domingo, requiring trial judges to refrain from accepting such pleas with alacrity and to first take testimony to verify the accused’s comprehension. The absence of this safeguard precluded the Supreme Court from exercising its constitutional duty of review to ensure the guilty plea was intelligent and voluntary. Consequently, the decision was vacated as to Agner and the records were remanded to the lower court for a new arraignment and proper proceedings.