Petitioner during his arraignment on August 20, 2009, accused-appellant pleaded “guilty” to the crime charged. The RTC found the plea to be voluntary and with full understanding of its consequences. Thus, it directed the prosecution to present evidence to prove the guilt of accused-appellant and to determine the exact degree of his culpability in accordance with Section 3,6 Rule 1167 of the 2000 Revised Rules of Criminal Procedure (2000 Revised Rules).
In its August 20, 2009 Order, the RTC, in specific recognition of the duties imposed by Sec. 3 of Rule 116, stated that let the trial and presentation of first prosecution witness to determine the culpability of the accused.
The Court issued a subpoena to Angelito Pagal, Cesar Jarden, and Emelita Calupas to appear and testify before it. However, after multiple issuances of subpoenas, the said witnesses failed to appear despite notice.
The defense chose not to present any evidence in view of the prosecution’s non-presentation. Both the prosecution and the defense moved for the submission of the case for decision.
October 5, 2011 Order, the RTC found accused-appellant guilty beyond reasonable doubt based solely on his plea of guilty. It stated that accused-appellant maintained his plea despite being apprised that he will be sentenced and imprisoned on the basis thereof.
The CA annulled and set aside the Order of the RTC and remanded the case for further proceedings in accordance with the guidelines to be observed in the proper conduct of a searching inquiry as required by Sec. 3, Rule 116 of the 2000 Revised Rules.
On appeal to the Supreme Court accused-appellant maintains that the RTC erred in convicting him on the sole basis of his guilty plea despite the failure of the prosecution to prove his guilt beyond reasonable doubt. He points to the fact that the prosecution was given numerous opportunities to present its evidence yet still failed to do so. He emphasizes that there is no evidence in support of his conviction except for his guilty plea. Considering that the prosecution failed to prove his guilt, the RTC should have dismissed motu proprio the action on the basis of insufficiency of evidence. He concludes that since his conviction was based solely on his improvident plea of guilt, the RTC should have acquitted him. Lastly, he also invokes the equipoise rule: since neither the prosecution nor the defense presented any evidence, the law should be tilted in his favor.
1. Whether the RTC properly conducted searching inquiry on the plea of guilty of the accused?
2. Whether the court may render a judgment of a capital offense solely on the plea of guilty of the accused?
1. No. The searching inquiry requirement means more than informing cursorily the accused that he faces a jail term but also, the exact length of imprisonment under the law and the certainty that he will serve time at the national penitentiary or a penal colony. The searching inquiry of the trial court must be focused on: (1) the voluntariness of the plea, and (2) the full comprehension of the consequences of the plea.
Further, a searching inquiry must not only comply with the requirements of Sec. 1, par. (a), of Rule 116 but must also expound on the events that actually took place during the arraignment, the words spoken and the warnings given, with special attention to the age of the accused, his educational attainment and socio-economic status as well as the manner of his arrest and detention, the provision of counsel in his behalf during the custodial and preliminary investigations, and the opportunity of his defense counsel to confer with him. These matters are relevant since they serve as trustworthy indices of his capacity to give a free and informed plea of guilt. Lastly, the trial court must explain the essential elements of the crime he was charged with and its respective penalties and civil liabilities, and also direct a series of questions to defense counsel to determine whether he has conferred with the accused and has completely explained to him the meaning of a plea of guilty. This formula is mandatory and absent any showing that it was followed, a searching inquiry cannot be said to have been undertaken.
2. No. the plea of guilty of an accused cannot stand in place of the evidence that must be presented and is called for by Sec. 3 of Rule 116. Trial courts should no longer assume that a plea of guilty includes an admission of the attending circumstances alleged in the information as they are now required to demand that the prosecution prove the exact liability of the accused. The requirements of Sec. 3 would become idle and fruitless if we were to allow conclusions of criminal liability and aggravating circumstances on the dubious strength of a presumptive rule.
For the guidance of the bench and the bar, this Court adopts the following guidelines concerning pleas of guilty to capital offenses:
1. AT THE TRIAL STAGE. When the accused makes a plea of guilty to a capital offense, the trial court must strictly abide by the provisions of Sec. 3, Rule 116 of the 2000 Revised Rules of Criminal Procedure. In particular, it must afford the prosecution an opportunity to present evidence as to the guilt of the accused and the precise degree of his culpability. Failure to comply with these mandates constitute grave abuse of discretion.
a. In case the plea of guilty to a capital offense is supported by proof beyond reasonable doubt, the trial court shall enter a judgment of conviction.
b. In case the prosecution presents evidence but fails to prove the accused’s guilt beyond reasonable doubt, the trial court shall enter a judgment of acquittal in favor of the accused.
c. In case the prosecution fails to present any evidence despite opportunity to do so, the trial court shall enter a judgment of acquittal in favor of the accused.
In the above instance, the trial court shall require the prosecution to explain in writing within ten (10) days from receipt its failure to present evidence. Any instance of collusion between the prosecution and the accused shall be dealt with to the full extent of the law.
2. AT THE APPEAL STAGE:
a. When the accused is convicted of a capital offense on the basis of his plea of guilty, whether improvident or not, and proof beyond reasonable doubt was established, the judgment of conviction shall be sustained.
b. When the accused is convicted of a capital offense solely on the basis of his plea of guilty, whether improvident or not, without proof beyond reasonable doubt because the prosecution was not given an opportunity to present its evidence, or was given the opportunity to present evidence but the improvident plea of guilt resulted to an undue prejudice to either the prosecution or the accused, the judgment of conviction shall be set aside and the case remanded for re-arraignment and for reception of evidence pursuant to Sec. 3, Rule 116 of the 2000 Revised Rules of Criminal Procedure.
c. When the accused is convicted of a capital offense solely on the basis of a plea of guilty, whether improvident or not, without proof beyond reasonable doubt because the prosecution failed to prove the accused’s guilt despite opportunity to do so, the judgment of conviction shall be set aside and the accused acquitted.