G.R. No. L-34674 August 6, 1979
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. PABLO GONZALES, defendant-appellant.

FACTS

Pablo Gonzales, a prisoner at the New Bilibid Prison, was charged with Murder for the stabbing death of fellow inmate Moises Malines on April 9, 1971. The information alleged the qualifying circumstance of treachery and the generic aggravating circumstance of evident premeditation. Initially pleading not guilty, Gonzales, assisted by counsel de oficio, later sought to withdraw that plea and substitute it with a plea of guilty. The trial court conducted a meticulous re-arraignment, ensuring Gonzales understood the consequences of his plea, including the possibility of the death penalty. Despite this warning, he insisted on pleading guilty.
In line with the doctrine in People vs. Flores, which requires the prosecution to present evidence to prove the accused’s guilt and the precise degree of culpability even after a guilty plea, the trial court allowed the prosecution to present its evidence. Witnesses testified that Gonzales and two companions, armed with improvised weapons, entered the ward after the door was opened on a signal. They pursued Malines inside, and a commotion ensued. The assailants were soon seen leaving with bloodied weapons, and Malines was found dead with 22 stab wounds. An extra-judicial confession from Gonzales, stating the killing was to avenge a slain gang member, was also presented.

ISSUE

Whether the trial court erred in accepting the accused’s plea of guilty and in finding the qualifying circumstance of treachery and the aggravating circumstance of evident premeditation to be present.

RULING

The Supreme Court affirmed the trial court’s judgment, including the imposition of the death penalty. The Court held that the acceptance of the substituted plea of guilty was proper. The trial judge meticulously complied with the duty to ensure the plea was made voluntarily and with full comprehension of its consequences, as required when the charge is a capital offense. The judge’s detailed questioning of Gonzales, confirmed by his counsel’s explanation in the dialect Gonzales understood, established a valid and intelligent plea.
Regarding the circumstances, the Court ruled that both treachery and evident premeditation were sufficiently established. Treachery was correctly inferred from the mode of attack: the sudden and unexpected entry of armed assailants who immediately pursued the unarmed victim inside the ward, resulting in multiple fatal wounds, some indicating an attack from behind. Evident premeditation was proven by Gonzales’s own extra-judicial confession, which detailed the planning of the killing the day before to exact vengeance. Furthermore, by pleading guilty to the information that specifically alleged these circumstances, Gonzales is deemed to have admitted all material facts alleged therein, including the attendant qualifying and aggravating circumstances. The judgment of conviction was thus affirmed in toto.