G.R. No. L-14783 - People vs. Ama y Perez

On August 27, 1958, Almario Bautista was fatally stabbed inside the New Bilibid Prison, Muntinlupa, Rizal.
The stabbing was carried out by the accused—Marcial Ama y Perez, Ernesto de Jesus, and Alejandro Ramos—armed with sharp-pointed instruments.
The attack was committed with treachery, evident premeditation, and in the presence of public authorities performing their duties.
The information charged the accused with murder and specified that the crime was committed amid a conspiratorial act by them.

Ernesto de Jesus and Alejandro Ramos moved for postponement to give the fiscal an opportunity to reinvestigate.
Marcial Ama y Perez moved to change his plea from not guilty to guilty.

The court granted Ama y Perez’s motion to substitute his plea, ensuring that the information was read and explained again to him.
With the assistance of counsel de oficio, Ama y Perez voluntarily pleaded guilty to the charge.

The information contained the special aggravating circumstance of quasi-recidivism, noting that the accused had previously been convicted and were serving sentences.
Defense counsel moved for the imposition of the minimum penalty based on the plea of guilty.
The prosecution objected, arguing that the mitigating plea of guilty could not offset the aggravating circumstance, thereby warranting the maximum penalty or even death.
Subsequent evidentiary submissions by the fiscal supported the presence of the aggravating circumstances.
Consequently, the trial court sentenced Marcial Ama y Perez to the death penalty, ordered payment of indemnity (P6,000.00) to the heirs of the deceased, and imposed the costs of the proceedings.

The trial court erred in allowing him to change his plea without informing him that his guilty plea would not counterbalance the aggravating circumstance.
Had he been properly advised, he would have opted for a trial rather than pleading guilty.
His counsel de oficio failed in adequately advising him regarding the implications based on Article 160 of the Revised Penal Code concerning quasi-recidivism.

Whether the trial court erred in allowing Marcial Ama y Perez to change his plea from not guilty to guilty without advising him that the mitigating effect of a plea of guilty would not offset the special aggravating circumstance of quasi-recidivism.

The central query is if the court's duty extended to informing the accused of the full extent of the consequences, including the imposition of the death penalty, upon entering a guilty plea.
If the oversight by the counsel in advising the accused regarding Article 160 of the Revised Penal Code is sufficient grounds for reversing the plea and the subsequent sentence.

Whether the evidence presented at the trial sufficiently supported the imposition of the death penalty based solely on the plea of guilty combined with the presence of aggravating circumstances.

Consideration was given to whether the trial court was obliged to require further evidence after the guilty plea.
The issue also encompasses whether the presumption of regularity in the performance of the counsel de oficio’s duties has been negated by the accused’s appeal.

Whether the discretion exercised by the trial court and the consequent sentencing was within the realm of judicial propriety, given the circumstances of the case.