GR L 37014; (April, 1984) (Digest)
G.R. No. L-37014 April 6, 1984
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MANUEL GAYOLA, ENRIQUE ARUTA, EDUARDO MURILLO, TENORIO AYUCAN, SALVADOR AYUCAN and CRUZ ABRASADO, accused, TENORIO AYUCAN, SALVADOR AYUCAN and CRUZ ABRASADO, accused-appellants.
FACTS
Accused-appellants Tenorio Ayucan, Salvador Ayucan, and Cruz Abrasado, along with three others, were charged with Robbery in Band with Triple Homicide and Rape. The information alleged that on September 30, 1971, in Valencia, Bukidnon, the accused, armed with bolos, conspired to rob the house of Delfin Redito. On the occasion of the robbery, they killed Delfin Redito and Silvino Maglinto, and then raped and killed Milagros Roa. The prosecution had no eyewitnesses and relied primarily on the extrajudicial confessions of the three appellants, which were taken without the assistance of counsel. During arraignment on April 13, 1972, the three appellants pleaded guilty. The trial court’s record merely states the pleas were entered without showing that the information was read to them or its contents explained in a dialect they understood.
ISSUE
Whether the trial court committed a reversible error in accepting the appellants’ pleas of guilty and convicting them based on an improvident plea.
RULING
Yes. The Supreme Court set aside the conviction and death sentence, remanding the case for further proceedings. The legal logic centers on the constitutional and procedural requirements for a valid plea of guilty, especially in capital offenses. A plea of guilty must be based on a full and complete comprehension of the charge and its consequences. The trial court has a duty to ensure the accused understands the nature of the crime, the allegations, and the severity of the penalty.
The record was utterly deficient. It failed to show that the trial judge conducted the requisite “searching inquiry” into the voluntariness and full comprehension of the plea. There was no indication the information was read or interpreted to the appellants in a language they understood. The judge’s only participation was instructing, “All right, arraign the accused.” This bare record rendered the plea improvident. Furthermore, the conviction heavily relied on extrajudicial confessions taken without counsel. While the 1971 investigation predated the explicit constitutional application of the right to counsel during custodial investigation, the totality of the procedural defects—the invalid plea and the questionable confessions—deprived the appellants of due process. The case required a new trial to ensure a proper arraignment and to allow the prosecution to prove its case through competent evidence.