G.R. No. L-66945 July 9, 1986
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EDUARDO BANDOJO and MAMERTO ARTUZ, accused-appellants.
FACTS
Accused-appellants Eduardo Bandojo and Mamerto Artuz were charged with Piracy under P.D. 532 for fatally shooting Consolacion Alfar, taking her money, throwing her body overboard, and forcing other passengers to jump into the sea in Bantayan, Cebu, on June 15, 1983. They initially gave extrajudicial confessions which the Court rejected for being taken without observance of their constitutional rights. At their formal arraignment, however, both entered separate pleas of guilty to the capital offense.
The trial judge did not immediately sentence them. Instead, he conducted a searching inquiry over two separate hearings to ensure they fully understood the nature of the charge and the consequences of their pleas. During this inquiry, both appellants made statements seemingly minimizing their roles or blaming each other. Bandojo denied conspiracy, claiming Artuz was the principal, while Artuz claimed he was forced by Bandojo. Despite these narratives, both appellants insisted on maintaining their guilty pleas and ultimately retracted their earlier qualifying statements, affirming their desire to plead guilty and throwing themselves on the mercy of the court. Convinced of the voluntariness and intelligence of their pleas, the trial court convicted them and imposed the death penalty.
ISSUE
Whether or not the trial court validly accepted the accused-appellants’ pleas of guilty and correctly convicted them without conducting a full trial on the merits.
RULING
Yes, the guilty pleas were validly accepted. The general rule in capital offenses is that a trial court must be circumspect in accepting a guilty plea. It must conduct a searching inquiry to ensure the plea is voluntary and made with full comprehension of its consequences. Furthermore, under the doctrine in People vs. Balisacan, if an accused enters a guilty plea but later testifies in a manner essentially constituting a denial or a defense (like complete self-defense), that testimony vacates the plea, and the court should direct a new plea of not guilty and proceed to trial.
The Court found that the present case constitutes a recognized exception to the mandatory duty to receive evidence. Here, the trial judge meticulously complied with his duty of a searching inquiry across two hearings. While the appellants initially made statements attempting to blame each other, they subsequently retracted these and unequivocally reaffirmed their guilty pleas. The Court emphasized that the trial judge’s probing yet fair questioning demonstrated his earnest effort to ascertain the truth and ensure the appellants’ understanding. Their ultimate and consistent insistence on pleading guilty, even while hoping for leniency, showed they were not vacating their pleas but affirming them. Therefore, their pleas were knowingly and voluntarily made. The conviction was upheld, but for lack of the necessary votes, the death penalty was reduced to reclusion perpetua.