G.R. No. L-58678-80 July 20, 1982
THE PEOPLE OF THE PHILIPPINES, petitioner, vs. JUDGE IRINEO V. MENDOZA of the Court of First Instance of Quezon, Mauban Branch V and ANDY DE LOS SANTOS, JR., respondents.

FACTS

Andy de los Santos, Jr. was charged with three counts of estafa for issuing dishonored checks. Initially pleading not guilty, he later withdrew that plea and substituted it with a plea of guilty during a hearing on September 7, 1981. The respondent judge conducted a thorough interrogation, ensuring the accused understood the consequences of his plea, which was entered voluntarily with the assistance of counsel. Considering the mitigating circumstances of plea of guilty and voluntary surrender, the court rendered three separate judgments of conviction on the same day, imposing indeterminate penalties.
Three days later, on September 10, 1981, the accused, through counsel, filed a motion to set aside the judgments. The motion merely cited an intent to substitute the plea with not guilty under Section 6, Rule 118 of the Rules of Court, without stating any factual or legal basis, and was not set for hearing. The trial court granted the motion in an order dated September 14, 1981, noting the judgments were not yet final, set them aside, entered a plea of not guilty for the accused, and scheduled trial. Subsequent motions for reconsideration by the prosecution were denied. When the prosecution failed to present witnesses on the reset dates, the court dismissed the cases and ordered the accused’s release.

ISSUE

Whether the trial court committed grave abuse of discretion in setting aside the judgments of conviction based on a plea of guilty and subsequently dismissing the criminal cases.

RULING

Yes, the trial court gravely abused its discretion. While Section 6, Rule 118 allows a court to permit the withdrawal of a plea of guilty and set aside a judgment before it becomes final, this power is not unbridled. It must be exercised based on compelling reasons such as fraud, mistake, or manifest injustice, and not merely upon the accused’s whimsical request. The accused’s motion was fatally defective: it provided no rational basis or assertion of a meritorious defense for the desired change of plea, and it was not set for hearing, depriving the prosecution of an opportunity to be heard.
The Supreme Court emphasized that when the record, as in this case, conclusively shows the accused entered his plea of guilty freely, voluntarily, and with full comprehension of its consequences after judicial interrogation, he shall not be allowed to withdraw it capriciously. The trial court’s summary grant of the motion, treating the change of plea as a matter of right simply because the judgment was not final, disregarded the respect due to its own solemn judgments and constituted a grave abuse of discretion amounting to lack or excess of jurisdiction. Consequently, the orders setting aside the judgments, allowing the change of plea, and dismissing the cases were reversed and set aside. The original judgments of conviction were reinstated and declared final and executory.