G.R. No. L-15633 - People vs. Ala y Duran

Accusation and charge against the accused
Defendant Primitivo Ala was accused, together with Nicolas Mojica, of murder committed on or about the 24th day of March, 1959, at the New Bilibid Prison, municipality of Muntinlupa, province of Rizal, Philippines.
The information alleged that the accused conspired and confederated, and mutually helped one another, armed with deadly weapons described as sharp-pointed instruments, with intent to kill with evident premeditation and treachery.
The information alleged that the accused wilfully, unlawfully and feloniously stabbed Ruperto Artus y Garcia on different parts of his body, inflicting several stab-wounds, which caused his death instantaneously.
The information additionally alleged that the accused were quasi-recidivists, having committed the felony while serving sentence after final conviction.
The information concluded with the allegation “Contrary to law.”

Plea and disposition in the Court of First Instance
Upon arraignment, Ala pleaded guilty, while Mojica pleaded not guilty.
The Court of First Instance of Rizal rendered judgment sentencing Ala to the extreme penalty, requiring him to indemnify the heirs of the deceased Ruperto Artus y Garcia in the amount of P6,000, and ordering him to pay the costs.
The trial proceeded as to Mojica.

Submission for review en consulta
The case reached the Supreme Court en consulta as to Ala, due to the nature of the penalty imposed.
Counsel de oficio for Ala, Atty. Erlinda Arce Ignacio Espiritu, submitted a brief stating that:

Because of the absence of evidence in the records, attributed to Ala’s plea of guilty and the fact that the records were not transcribed before filing the brief, she attempted to ascertain Ala’s participation.
She relied on information supposedly furnished by Ala and Mojica, which she treated as hearsay, the veracity of which she could not assure.
She doubted whether Ala had sufficient knowledge of the meaning and consequences of his guilty plea and whether he perpetrated the crime.
She prayed that the records be remanded to the lower court for reception of evidence and/or a new trial.

The Office of the Solicitor General filed a brief that reached a similar conclusion and recommended remand, based on analogous considerations.
After submission, the transcript of the proceedings when Ala entered his plea of guilty and was sentenced was attached to the record.
In the meantime, after due trial, Mojica was also convicted by the lower court and sentenced to the same penalty, and the decision against Mojica dated June 6, 1960 was also before the Supreme Court pending review en consulta.

After advising Ala of the contents of the information, Ala “manifested his desire to plead guilty”.
Counsel explained the consequences of the plea.
Despite the explanation, Ala expressed determination to plead guilty “as he really committed the acts alleged in the information”.
Mojica would plead not guilty.

The court asked whether the accused were ready to plead; counsel answered in the affirmative, and arraignment proceeded.
The court interpreter read and translated the information to the accused.
Ala pleaded guilty, while Mojica pleaded not guilty.
The court asked Ala whether he understood the information as read and translated; Ala answered affirmatively.
The court asked whether Ala pleaded guilty freely and voluntarily, without coercion, intimidation, or promised reward or immunity; Ala gave an affirmative answer.
The court asked whether Ala was aware that in pleading guilty he would be liable to be sentenced according to the law governing the case; Ala answered “Yes, Your Honor.”
The Court of First Instance then rendered judgment sentencing Ala.

Underlying events supporting the guilty plea and conviction context
The Supreme Court considered the conviction against Mojica as bolstering the conclusion that Ala understood his plea.
The decision against Mojica disclosed that Gabriel Buclatin, a leader of the “OXO Gang,” was killed by several members of the “Sigue-Sigue Gang” inside the New Bilibid Prison on March 24, 1954, at about 4:15 p.m.
Upon being apprised of the incident, Ala and Mojica, m...(Subscriber-Only)

Whether Ala’s guilty plea was entered with sufficient knowledge of the meaning and consequences of the plea
Whether the absence of evidence in the records at the time of briefing warranted remand for reception of evidence or a new trial, in light of counsel’s doubt about Ala’s knowledge when he pleaded guilty.

Whether Ala’s plea of guilty and circumstances surrounding it warranted affirmance of the conviction and the extreme penalty
Whether the transcript of arraignment and the court’s inquiries sufficiently established that Ala understood the charge, the connotations of pleading guilty, and the consequences under the applicable law.
Whether ...(Subscriber-Only)