GR L 32571 72; (December, 1979) (Digest)
G.R. No. L-32571-72 December 27, 1979
PEOPLE OF THE PHILIPPINES, plaintiff, vs. JUANITO PAJARILLO and ALMARIO RODRIGUEZ, accused.
FACTS
Two separate informations for murder were filed against accused-appellants Juanito Pajarillo and Almario Rodriguez, prisoners at the New Bilibid Prisons, for the stabbing deaths of fellow inmates Roque Danao and Reynaldo Guevarra during a gang riot between the BRM and Sigue-Sigue Sputnik gangs on December 6, 1969. The informations alleged the qualifying circumstances of treachery and evident premeditation, and the aggravating circumstance of taking advantage of superior strength. Initially pleading not guilty, the accused, assisted by counsel de oficio, later withdrew their pleas and requested re-arraignment to plead guilty. The trial court informed them of the death penalty consequence, but they persisted. The court then accepted the pleas and immediately sentenced both accused to death for each murder.
ISSUE
Whether the trial court erred in accepting the pleas of guilty and imposing the death penalty without requiring the prosecution to present evidence to prove the culpability of the accused and the attendant qualifying and aggravating circumstances.
RULING
Yes. The Supreme Court set aside the death sentences. While a plea of guilty admits all material facts in the information, jurisprudence mandates extreme caution in capital offenses. The trial court must ensure the plea is voluntary, intelligent, and with full comprehension of its consequences, often requiring the prosecution to still present evidence to establish guilt and the precise degree of culpability. Here, the Court found the plea improvident. The record lacked sufficient evidence to prove the alleged qualifying circumstances. Treachery and abuse of superior strength were not established by evidence, and evident premeditation was only substantiated against Pajarillo, not Rodriguez, who acted on a sudden impulse. Without these circumstances, the crimes committed were homicide, not murder, warranting a lower penalty. The case was remanded to the trial court for reception of evidence to properly determine the correct classification of the offenses and the appropriate penalties. The mitigating circumstance of plea of guilty was noted for Pajarillo, but not for Rodriguez, whose plea was deemed improvident.