G.R. No. L-35279 July 30, 1979
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. PORFIRIO DUMDUM, JR. and RENATO PERALTA, defendants.

FACTS

This case is an automatic review of a death sentence. Defendants Porfirio Dumdum, Jr. and Renato Peralta, both prisoners at the New Bilibid Prison, were convicted of murder for the killing of fellow inmate Dionisio Macadangdang on September 7, 1971. The victim sustained multiple fatal stab wounds. The accused, members of the “Happy Go Lucky” gang, confessed that they planned the assault an hour in advance to avenge an attack on their gang leader by a rival group. They waited for the unarmed victim and attacked him treacherously as he passed by.
During arraignment, with the assistance of counsel de oficio, both accused pleaded guilty to the charge. The trial judge informed them of the consequence of their plea, including the mandatory death penalty under Article 160 of the Revised Penal Code for quasi-recidivists. They affirmed their understanding and voluntariness. Subsequently, the court held a hearing where the prosecution presented evidence, including the confessions, autopsy report, and weapons, which were cross-examined by the defense counsel. The trial court then sentenced them to death.

ISSUE

The core issue is whether the trial court erred in convicting the accused and imposing the death penalty based on their plea of guilty, considering the procedural irregularity in the sequence of the proceedings.

RULING

The Supreme Court affirmed the conviction and the imposition of the death penalty. The Court held that the trial court adequately ensured the plea was not improvident by interrogating the accused on their understanding of its consequences. Their judicial confessions were substantiated by independent prosecution evidence, which was sufficient to convict them beyond reasonable doubt even absent the plea. The crime was murder qualified by treachery, as the accused deliberately surprised the unarmed victim without opportunity for defense. The special aggravating circumstance of quasi-recidivism, as both were serving sentences at the time of the crime, mandated the imposition of the death penalty, placing the applicable penalty in its maximum period. This circumstance rendered inoperative any mitigating factors, such as the plea of guilty.
The Court noted a procedural irregularity wherein the trial judge pronounced judgment immediately after the plea and later required evidence presentation. However, this error did not vitiate the conviction, as the evidence overwhelmingly supported it. The Court advised trial judges to follow the correct sequence: present evidence after arraignment and render judgment thereafter. Furthermore, the Court ruled that the constitutional safeguards on custodial interrogation (1973 Constitution, Sec. 20, Art. IV) were inapplicable, as the confessions were obtained before its effectivity and their voluntariness was never challenged. The penalty was justified by precedent cases involving prisoner-on-prisoner killings. The judgment was affirmed.