GR L 35877; (December, 1974) (Digest)
G.R. No. L-35877 December 20, 1974
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. QUINTINO “BOY” YBAÑEZ, ET AL., defendants, QUINTINO “BOY” YBAÑEZ, defendant-appellant.
FACTS
Quintino “Boy” Ybañez and six others were charged with the complex crime of robbery with homicide and rape. Ybañez initially pleaded not guilty. After an escape and recapture, his case proceeded with multiple changes in his appointed counsel de oficio. On November 27, 1968, the trial court noted Ybañez’s willingness to plead guilty despite being apprised that the charge, being a complex crime, could result in the death penalty. The arraignment was postponed several times. Finally, on April 10, 1969, with yet another newly appointed counsel de oficio “for purposes of arraignment only,” Ybañez was allowed to withdraw his prior not guilty plea and substitute a plea of guilty. The trial court immediately sentenced him to death, prompting this automatic review.
ISSUE
Whether the trial court erred in convicting and sentencing Ybañez to death based solely on his substituted plea of guilty without ensuring he fully understood its consequences and without taking evidence to ascertain the precise degree of his culpability.
RULING
Yes. The Supreme Court set aside the judgment and remanded the case for new arraignment and further proceedings. The transcript revealed the trial court failed to take the necessary steps to ensure the plea of guilty was not improvidently entered. The court merely reminded Ybañez it was a case of “robbery with homicide and rape” and informed him the “least” he could get was “the electric chair.” This cursory inquiry was insufficient, especially given Ybañez’s prior not guilty pleas and the capital nature of the offense. The Court reiterated the doctrine from People vs. Apduhan that judges must be “extra solicitous” in ensuring an accused understands the full meaning and consequences of a guilty plea in capital cases. Furthermore, following People vs. Lacson and People vs. Busa, the trial court should have taken testimony notwithstanding the plea. This is required to establish the guilt and precise degree of culpability, to satisfy the trial judge, and to aid the Supreme Court in its mandatory review to determine if the accused truly comprehended the plea’s significance. The essence of review in capital offenses demands that a death sentence be based on a record susceptible to fair and reasonable examination to prevent any miscarriage of justice.