Case Digest (G.R. No. L-15633)
Facts:
The People of the Philippines v. Primitivo Ala y Duran, G.R. No. L-15633, August 31, 1960, the Supreme Court En Banc, Per Curiam. The prosecution charged Primitivo Ala y Duran and Nicolas Mojica with murder alleged to have been committed on or about 24 March 1959 inside the New Bilibid Prison, Muntinlupa, Rizal. The information accused both defendants of conspiring, being armed with sharp instruments, and stabbing one Ruperto Artus y Garcia with evident premeditation and treachery; it also alleged that the accused were quasi-recidivists serving sentences after prior final conviction.At arraignment before the Court of First Instance of Rizal, Ala pleaded guilty while Mojica pleaded not guilty. The trial court sentenced Ala to the extreme penalty, ordered indemnity of P6,000 to the heirs of the deceased, and imposed costs; the court then proceeded to try Mojica. Because Ala received the death penalty, his case was submitted to the Supreme Court en consulta.
Counsel de oficio for Ala and the Office of the Solicitor General filed briefs suggesting remand for reception of evidence or a new trial, noting that at the time of those briefs the transcript of the arraignment had not been transcribed and questioning whether Ala fully appreciated his plea. Subsequently, the transcript of the arraignment and plea hearing was added to the record, and after trial Mojica was convicted by the lower court (decision dated June 6, 1960), the facts of which were brought to the Court’s attention en consulta.
The arraignment transcript shows counsel represented that he advised Ala of the information’s contents, that Ala manifested his desire to plead guilty because “he really committed the acts alleged,” that the information was read and translated by the court interpreter, and that the court personally questioned Ala who answered affirmatively that he understood the information, that his plea was freely and voluntarily given, and that he was aware of the consequences of a guilty plea. The lower court’s adjudication of Mojica — including medical findings describing thirty-two puncture wounds and the prison doctor’s conclusion that death resulted from shock and internal hemorrhage, Mojica’s surrender with blood-stained clothing, his delivery of the weapon to a guard, and...(Pro-only)
Issues:
- Was Primitivo Ala y Duran’s plea of guilty entered knowingly, voluntarily and intelligently?
- Should the judgment of the Court of First Instance of Rizal convicting and sentencing Ala to death...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)