G.R. No. L-59054 November 2, 1982
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MUSTAPA ALIBASA alias “PHANKS”, et al., accused. MUSTAPA ALIBASA alias “PHANKS”, accused-appellant.

FACTS

The accused-appellant, Mustapa Alibasa, along with several others, was charged with the capital offense of Kidnapping for Ransom under Article 267 of the Revised Penal Code. The information alleged that on November 26, 1980, in Basilan, the accused, armed and part of a terrorist group, kidnapped Alejandro Guiroy, detained him under heavy guard until January 23, 1981, and secured a ransom of P20,000.00 for his release. All other accused remained at large. Initially, Alibasa pleaded not guilty. During trial, after the prosecution presented its first witness, Alibasa, through counsel, moved to change his plea to guilty. The trial court granted the motion, rearraigned him, and accepted the guilty plea.
Instead of requiring the prosecution to complete its presentation of evidence, the trial court immediately placed Alibasa on the witness stand. Subsequently, the court rendered a judgment convicting him and imposing the death penalty. The trial court, however, appended a recommendation for executive clemency. The case was elevated to the Supreme Court for automatic review.

ISSUE

Whether the trial court committed a reversible error in convicting the accused and imposing the death penalty based solely on his plea of guilty without requiring the prosecution to first complete the presentation of its evidence.

RULING

Yes. The Supreme Court set aside the judgment and remanded the case to the trial court for further proceedings. The legal logic is anchored on the mandatory duty of courts in cases involving capital offenses. When an accused pleads guilty to a capital offense, the court must not rely solely on that plea for conviction. Jurisprudence consistently mandates that the trial court must still require the prosecution to present evidence to prove the guilt and the precise degree of culpability of the accused.
This procedure is a crucial safeguard against any improvident or coerced plea and ensures that the conviction rests on a solid factual foundation, especially where the extreme penalty of death is involved. By proceeding to judgment immediately after the change of plea and the accused’s testimony, without allowing the prosecution to complete its case, the trial court deprived itself of the full factual basis necessary to determine the exact participation and liability of the appellant. The Solicitor General correctly recommended remand. The Supreme Court emphasized that taking testimony after a guilty plea in capital cases is the prudent and proper course to establish the facts beyond reasonable doubt.