G.R. No. L-33294. July 25, 1984.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RAFAEL V. SERNA and ANTONIO O. CIPRIANO, accused, RAFAEL V. SERNA, defendant-appellant.

FACTS

Accused Rafael Serna and Antonio Cipriano were charged with Robbery with Double Homicide before the Court of First Instance of Samar. The information alleged that on November 28, 1970, they conspired to rob P80.00 from Romualdo Villones and Leonardo Carlos, and on the occasion thereof, stabbed and killed both victims. The prosecution alleged the aggravating circumstances of use of a motorized banca for flight and, for Serna, recidivism. Upon arraignment, with the information read in English and translated to the Samar dialect, both accused pleaded guilty. Invoking the mitigating circumstance of plea of guilty, they were immediately sentenced.
The trial court rendered judgment, finding both guilty. It considered Cipriano’s plea of guilty as mitigating, offset by the aggravating circumstance of using a motorized banca, and sentenced him to reclusion perpetua. For Serna, the court found two aggravating circumstances (recidivism and use of a motorized banca) against him, with one offset by his plea of guilty, resulting in the imposition of the death penalty. The case was elevated to the Supreme Court for automatic review of Serna’s death sentence.

ISSUE

Whether the trial court committed a reversible error in accepting the accused’s plea of guilty and imposing the death penalty without taking further evidence to ascertain the precise culpability and ensure the plea was made with full comprehension.

RULING

Yes. The Supreme Court set aside the judgment and remanded the case to the trial court for further proceedings. The legal logic is anchored on the stringent procedural safeguards required in capital offenses. When an accused pleads guilty to a crime punishable by death, the trial court must exercise extraordinary diligence to ensure the plea is entered intelligently, voluntarily, and with full understanding of its consequences. Mere reading of the information and a translation, followed by an immediate plea, is insufficient.
The Court emphasized that the trial judge must not only explain the import of the plea and the severity of the penalty but must also require the prosecution to present evidence. This serves a dual purpose: to establish the guilt and precise degree of culpability of the accused, and to aid the reviewing Supreme Court in determining whether the plea was truly understandingly made. The trial court’s failure to conduct this mandatory evidentiary hearing, especially given the automatic review of a death sentence, constituted a grave procedural error. The case was therefore remanded for the reception of evidence to substantiate the plea and properly determine the correct penalty, in accordance with established jurisprudence.