G.R. No. L-69317 September 11, 1985
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DANILO BADILLA y ONES alias DODONG, accused-appellant.

FACTS

Danilo Badilla was charged with Robbery with Homicide under Article 294 of the Revised Penal Code for the killing of Nestora Horoboro and the taking of her electric fan and radio cassette recorder. The Information alleged the aggravating circumstances of treachery, obvious ungratefulness, and dwelling. Upon arraignment, Badilla, assisted by counsel, entered a plea of guilty. The trial court, in its decision dated October 31, 1984, noted that the accused affirmed his lawyer had explained the consequences of his plea. The court treated the plea as a mitigating circumstance but found it offset by the three aggravating circumstances, sentencing Badilla to death.
The case was elevated to the Supreme Court for automatic review. The accused-appellant, through his counsel de oficio, assailed the judgment, contending the trial court failed to ascertain whether he fully understood the nature of the charge and the consequences of his plea. He also argued the court erred in not receiving evidence to substantiate the alleged aggravating circumstances and in not keeping a record of the arraignment proceedings. The Solicitor General, in a Manifestation, confirmed the absence of a transcript of stenographic notes for the arraignment.

ISSUE

Whether the trial court committed reversible error in accepting the accused’s plea of guilty to a capital offense without conducting a proper searching inquiry and without taking evidence to establish his guilt and the attendant circumstances.

RULING

Yes. The Supreme Court set aside the judgment and remanded the case to the trial court for further proceedings. The Court emphasized the stringent requirements in cases where the accused pleads guilty to a capital offense. Jurisprudence mandates that the trial court must conduct a searching inquiry to ensure the plea is made voluntarily, with full comprehension of the charge and its consequences. The court must explain the nature of the accusation and the effects of the attendant circumstances alleged.
Merely asking the accused if his counsel explained the consequences is insufficient. The trial court must probe into what specific advice was given and, more critically, what the accused actually understood about the plea and its implications. Furthermore, the court should call witnesses to establish the guilt and the precise degree of culpability of the defendant. This procedure is not only for the satisfaction of the trial judge but also to aid the Supreme Court on review. Here, the trial court’s failure to conduct such an inquiry, compounded by the absence of a transcript of the arraignment, constituted a fatal defect. The acceptance of the plea was therefore improvident, warranting the remand of the case for proper proceedings to ascertain the true facts and the voluntariness and intelligence of the plea.