G.R. No. L-80845 March 14, 1994
PEOPLE OF THE PHILIPPINES, petitioner, vs. HON. ERNESTO M. MENDOZA, Presiding Judge, Regional Trial Court of Malaybalay, Bukidnon, Branch 10, and JUAN MAGALOP y SALVACION, respondents.

FACTS

On January 20, 1987, the storeroom of the Bukidnon National School of Home Industries (BNSHI) in Maramag, Bukidnon, was ransacked, with missing articles valued at P15,298.15. The police initially could not identify the culprits. Accused Juan Magalop y Salvacion, Petronilo Fernandez y Cano, and Ricarte Dahilan were charged with robbery with force upon things. At the arraignment on June 23, 1987, Magalop pleaded guilty, while Fernandez pleaded not guilty; Dahilan’s arraignment was deferred due to mental condition. Despite Magalop’s guilty plea, the trial court conducted a trial. The prosecution presented witnesses and evidence, including recovered tools (pliers and a saw) found in the possession of a certain Babie Tan, who was not presented as a witness. The defense waived its right to present evidence. On October 8, 1987, respondent Judge Ernesto M. Mendoza acquitted both Fernandez and Magalop, stating that the prosecution failed to prove the accused’s guilt beyond reasonable doubt and that Magalop’s plea was not intelligently made. The prosecution’s motion for reconsideration was denied.

ISSUE

Whether the trial court committed grave abuse of discretion in acquitting accused Juan Magalop despite his plea of guilt to the crime of robbery with force upon things.

RULING

The Supreme Court dismissed the petition and sustained the acquittal of Juan Magalop. The Court held that while a plea of guilty is an unconditional admission of guilt, it does not automatically result in conviction if the totality of evidence points to acquittal. The trial court found that the prosecution’s case was “virtually non-existent” as the stolen articles were found with Babie Tan, who was not presented to testify, and no evidence independent of the plea linked Magalop to the crime. The Court noted that the procedure followed by the trial judge was irregular, as he should have considered the plea withdrawn and entered a not guilty plea after finding it improvident, as established in People v. Padernal. However, in the interest of substantial justice and Magalop’s constitutional right to be presumed innocent, the acquittal was sustained because, outside of his improvident plea, there was absolutely no evidence against him. The Court also noted the petition was defective as it was filed by the Provincial Fiscal instead of the Solicitor General, but addressed the merits nonetheless.