G.R. No. L-35384 November 28, 1972
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ANGELITO MATIAS, ET AL., defendants, ANGELITO MATIAS and AGUSTIN DESCALSO, defendants-appellants.

FACTS

The case involves the automatic review of a death penalty decision from the Court of First Instance of Davao del Norte. Defendants-appellants Angelito Matias and Agustin Descalso, along with an at-large co-accused, were charged with the murder of fellow prisoner Hilario Luzano within the Kapalong Sub-Colony. During their arraignment on June 8, 1972, both accused, assisted by counsel de officio, pleaded guilty to the crime as charged. Their counsel invoked the mitigating circumstance of a spontaneous plea of guilty. The prosecution, however, recommended the imposition of the death penalty, arguing the presence of the special aggravating circumstance of quasi-recidivism under Article 160 of the Revised Penal Code, as the accused were serving final sentences at the time of the murder. The trial court noted this circumstance was not alleged in the information and thus could not be considered. Subsequently, the trial court rendered a decision convicting the appellants of murder and sentencing them to death.
The trial court’s decision was based on the appellants’ affidavits and their prison records, which detailed their prior convictions. The decision described the stabbing incident and the appellants’ subsequent escape and recapture. However, these affidavits and records were never formally offered or admitted into evidence during the proceedings. The Solicitor General, in a manifestation to the Supreme Court, highlighted this procedural flaw and the lack of any record showing that the trial court had adequately explained the charges and the consequences of a guilty plea to the appellants before accepting it.

ISSUE

Whether the trial court committed reversible error in accepting the appellants’ plea of guilty and imposing the death penalty based on evidence not formally offered and without ensuring the appellants fully understood the implications of their plea.

RULING

Yes. The Supreme Court set aside the trial court’s decision and remanded the case for new trial. The Court emphasized the fundamental requirement of utmost care in cases where a plea of guilty is entered, especially when the imposable penalty is death. The legal logic is anchored on the necessity of a searching inquiry by the trial judge to ensure the accused comprehends the nature of the charge, the meaning of a guilty plea, and its severe consequences. The record in this case was devoid of any indication that such an explanation was made to appellants Matias and Descalso.
Furthermore, the Court found a critical procedural error. The trial judge based the conviction and penalty on the appellants’ affidavits and prison records, which were attached to the case folder but were never formally offered in evidence by the prosecution. Evidence not formally offered has no probative value and cannot be legally considered in deciding a case. This error deprived the appellants of their right to a fair trial and to confront the evidence against them. Consequently, the Supreme Court could not perform its duty of automatic review with sufficient and reliable data. The Court, agreeing with the Solicitor General’s recommendation and citing precedents like People v. Apduhan and People v. Baylosis, held that a remand was necessary to rectify these errors and to allow the case to proceed with the proper observance of procedural and substantive due process.