G.R. No. L-33709-10 March 28, 1974
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CEFERINO DAQUIOAG and DANILO DOMINGO, defendants-appellants.

FACTS

Ceferino Daquioag and Danilo Domingo, together with Lorenzo de la Peña, were charged with two counts of forcible abduction with rape before the Court of First Instance of Cagayan. The informations alleged that on October 14, 1969, in Lal-lo, Cagayan, armed with guns and a razor, they abducted Magdalena Urbi and Lydia Urbi. Daquioag was accused of raping Magdalena, and Domingo of raping Lydia. Initially, all accused pleaded not guilty. However, on March 24, 1971, Daquioag and Domingo, through counsel, moved to withdraw their not guilty pleas and enter pleas of guilty instead.
The trial court, in its order, detailed the proceeding: it warned the accused that even with a guilty plea, the death penalty might still be imposed. After a conference with their counsel and a recess for further meditation, the accused reiterated their desire to plead guilty. The court granted the withdrawal of their former pleas and re-arraigned them, upon which both entered a plea of guilty in each case. The court subsequently rendered a decision imposing the death penalty on each accused for both counts. The case is now on automatic appeal.

ISSUE

Whether the trial court committed reversible error in accepting the accused-appellants’ pleas of guilty to a capital offense without conducting a searching inquiry to ensure the pleas were made voluntarily, with full understanding of the charges and consequences.

RULING

Yes, the trial court erred. The Supreme Court set aside the judgment and remanded the case for a new arraignment and further proceedings. The legal logic is anchored on the stringent requirements for accepting a guilty plea in capital offenses to prevent improvidence. While the trial court warned of the possible imposition of the death penalty and gave time for meditation, its inquiry was insufficient. First, it failed to ascertain the reasons for the accused’s sudden reversal from pleas of not guilty to guilty. Such a turnabout, without explanation, remains suspect, as it could stem from a mistaken belief that conviction was inevitable, perhaps due to the existence of unproven extrajudicial confessions.
Second, the court did not conduct a “searching inquiry” to determine if the accused fully comprehended the precise allegations and the gravity of the charges. The informations were technically phrased, and the accused were young and unschooled (Domingo was 16, Daquioag was 20), necessitating a patient, detailed explanation from the court itself. Finally, the prudent course in capital cases after a guilty plea is to take testimony to establish the guilt and factual basis of the plea. This procedure would dispel any doubt regarding the accused’s understanding and the voluntariness of their action. The attached extrajudicial confessions provided no comfort as they were not formally offered or proven to be voluntary. Thus, the acceptance of the plea was improvident, violating the accused’s right to due process.