G.R. No. L-33028 June 30, 1972
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CIRILO ESPIÑA, defendant-appellant.

FACTS

An information was filed against Cirilo Espiña for the murder of Antonio Rosendal, allegedly committed with treachery. The information also alleged the aggravating circumstance of recidivism, citing a prior conviction for robbery with frustrated homicide. During arraignment on December 15, 1970, a counsel de oficio was appointed for the accused. After a brief suspension of less than an hour for consultation, the hearing resumed, and the accused, through counsel, pleaded guilty to the charge. The defense invoked the mitigating circumstances of obfuscation, voluntary surrender, and plea of guilty.
The trial court, however, found the accused guilty of murder. It ruled that while the allegation of recidivism was incorrect, the accused was a quasi-recidivist under Article 160 of the Revised Penal Code, as he committed the new felony while serving a sentence from his prior conviction. The court held that quasi-recidivism could not be offset by the mitigating circumstances pleaded. Consequently, it imposed the death penalty, citing that the maximum period for murder is death.

ISSUE

Whether the trial court committed a reversible error in accepting the plea of guilty and imposing the death penalty without conducting a searching inquiry into the voluntariness and consequences of the plea and without taking evidence to determine the precise degree of culpability.

RULING

Yes. The Supreme Court set aside the death sentence and remanded the case for a new trial. The Court emphasized the rigid standard required in capital cases when an accused pleads guilty. The trial judge must conduct a searching inquiry to ensure the plea is voluntary, intelligent, and made with full comprehension of its consequences, especially where the death penalty is a possibility.
The record revealed a fatal infirmity in the proceedings. The appointment of counsel de oficio and the subsequent plea occurred within an unreasonably short period, indicating a lack of meaningful consultation. The trial court failed to explain the nature of the charge, particularly the grave implication of quasi-recidivism under Article 160, and the severity of the death penalty. Moreover, the court did not take any evidence to ascertain the precise circumstances of the crime and the accused’s degree of culpability before imposing the supreme penalty. This omission violated the due process rights of the accused. Both the defense and the prosecution concurred in seeking the remand, recognizing the lower court’s failure to adhere to the meticulous standards mandated by jurisprudence for capital cases.