People vs. Pagal, G.R. No. 241257, September 29, 2020

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, Rule 116 of the 2000 Revised Rules of Criminal Procedure (2000 Revised Rules).

During the Presentation of evidence of the prosecution, the prosecution failed to present any witness against the accused despite multiple subpoena issued by the RTC.

The RTC found the accused guilty beyond reasonable doubt and sentenced to suffer the imprisonment of Reclusion Perpetua.

Accused-appellant appealed the RTC Order to the CA and raised this singular error that the trial court erred in convicting the accused-appellant of the crime charged solely on the basis of the latter’s plea of guilt and despite the failure of the prosecution to prove his guilt beyond reasonable doubt.

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. Hence, this recourse.

1. Whether the RTC erred in convicting the accused of the crime charged solely on the basis of the latter’s plea of guilt and despite the failure of the prosecution to prove his guilt beyond reasonable doubt.

2. Whether the plea of guilt made by the accused does not relieve the prosecution of the duty to prove the guilt of the accused beyond reasonable doubt.

3. Whether the accused must be given a reasonable opportunity to present evidence despite latter’s plea of guilt.


1. Yes, in every case where the accused enters a plea of guilty to a capital offense, especially when he is ignorant with little or no education, the proper and prudent course to follow is to take such evidence as are available and necessary in support of the material allegations of the information, including the aggravating circumstances therein enumerated, not only to satisfy the trial judge himself but also to aid the Supreme Court in determining whether the accused really and truly understood and comprehended the meaning, full significance, and consequences of his plea. In particular, trial courts are mandated to conduct the searching inquiry.

Corollary to this duty, a plea of guilty to a capital offense without the benefit of a searching inquiry or an ineffectual inquiry, as required by Sec. 3, Rule 116 of the 2000 Revised Rules, results to an improvident plea of guilty. It has even been held that the failure of the court to inquire into whether the accused knows the crime with which he is charged and to fully explain to him the elements of the crime constitutes a violation of the accused’s fundamental right to be informed of the precise nature of the accusation against him and a denial of his right to due process.

2. Yes, the reason behind this requirement is that the plea of guilt alone can never be sufficient to produce guilt beyond reasonable doubt. It must be remembered that a plea of guilty is only a supporting evidence or secondary basis for a finding of culpability, the main proof being the evidence presented by the prosecution to prove the accused’s guilt beyond reasonable doubt. Once an accused charged with a capital offense enters a plea of guilty, a regular trial shall be conducted just the same as if no such plea was entered. The court cannot, and should not, relieve the prosecution of its duty to prove the guilt of the accused and the precise degree of his culpability by the requisite quantum of evidence. The reason for such rule is to preclude any room for reasonable doubt in the mind of the trial court, or the Supreme Court on review, as to the possibility that the accused might have misunderstood the nature of the charge to which he pleaded guilty, and to ascertain the circumstances attendant to the commission of the crime which may justify or require either a greater or lesser degree of severity in the imposition of the prescribed penalties. Thus, as it stands, the conviction of the accused no longer depends solely on his plea of guilty but rather on the strength of the prosecution’s evidence.

3. Yes, to allow the accused to present exculpatory or mitigating evidence on his behalf in order to properly calibrate the correct imposable penalty. This duty, however, does not mean that the trial court can compel the accused to present evidence. Of course, the court cannot force the accused to present evidence when there is none. The accused is free to waive his right to present evidence if he so desires. To protect the constitutional right to due process of every accused in a capital offense and to avoid any confusion about the proper steps to be taken when a trial court comes face to face with an accused or his counsel who wants to waive his client’s right to present evidence and be heard, it shall be the unequivocal duty of the trial court to observe, as a prerequisite to the validity of such waiver, a procedure akin to a searching inquiry.


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