G.R. No. L-7929 November 29, 1955
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. PEDRO GAITE, defendant-appellant.

FACTS

The defendant-appellant, Pedro Gaite, was charged with parricide in the Court of First Instance of Romblon. At the initial hearing on January 27, 1954, the court appointed Atty. Enrique Javier as his counsel de oficio, and the hearing was postponed. At the hearing on June 2, 1954, the appellant, assisted by Atty. Javier, pleaded guilty upon arraignment. The court then rendered a decision finding him guilty of parricide and, considering his lack of instruction and voluntary plea of guilty, sentenced him to reclusion perpetua with accessory penalties, to indemnify the heirs of the deceased Elias Gaite in the sum of P6,000 without subsidiary imprisonment, and to pay the costs. The appellant appealed.

ISSUE

The issues raised on appeal were whether the lower court erred: (1) in not allowing the appellant to make an explanation after his plea of guilty, and (2) in not considering the doubt as to whether he is the legitimate son of the deceased Elias Gaite.

RULING

The Supreme Court affirmed the appealed decision. On the first issue, the Court held that the record of the proceedings on June 2, 1954, exclusively showed that the appellant, aided by his counsel, “entered the plea of guilty in open court,” thereby admitting both his guilt and the material allegation in the information that he is the legitimate son of the deceased. There was no pretense that the appellant was forced to plead guilty; he was assisted by his attorney de oficio who was reminded by the court about the effect of a qualified plea of guilty and had the opportunity to adopt the proper course. On the second issue, the Court ruled that alleged testimony from the preliminary investigation (by Paula Guituilian and Jose Lorenzo) suggesting doubt as to appellant’s legitimacy could not be taken into account as it was not part of the proceedings in the lower court.