Title
People vs. Bacong
Case
G.R. No. L-36161
Decision Date
Dec 19, 1973
The Supreme Court sets aside a guilty plea in the case of People v. Bacong, ruling that the lower court failed to properly explain the consequences of the plea to the defendant, violated the rule of unconditional admission of guilt, and undermined the defendant's constitutional rights, emphasizing the need for lower courts to exercise utmost care in accepting guilty pleas and ensuring the accused fully understands the consequences.
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Case Digest (G.R. No. L-36161)

Facts:

  • Defendant Regino Bacong was charged with murder.
  • During his arraignment, the lower court accepted Bacong's plea of guilty.
  • The information was written in a language Bacong was not familiar with.
  • The lower court failed to fully explain the consequences of the guilty plea to Bacong.
  • The court's decision required the prosecution to present evidence of Bacong's guilt, even though the guilty plea had already been accepted.
  • Bacong was an illiterate person who did not fully understand the legal significance of the allegations against him.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled in favor of the defendant, setting aside the guilty plea and reversing the lower court's decision.
  • The court held that the lower court failed to properly explain the consequences of the guilty plea to the defendant, violating the defendant's constitutional rights.
  • The court also found that the lower court's decision to require the prosecution to present evidence after accepting the guilty plea was a violation o...(Unlock)

Ratio:

  1. The court emphasized the need for lower courts to exercise utmost care in accepting pleas of guilty and to ensure that the accused fully understands the consequences of such a plea.
  2. This requirement is rooted in the presumption of innocence and the right to procedural due process.
  3. The court cited previous decisions that highlighted the importance of an accused being fully aware of the consequences of a guilty plea.
  4. The court noted that the lower court failed to follow the guidelines set by the Supreme Court in conducting arraignments for accused persons pleading guilty to offenses carrying capital punishment.
  5. The court found that the lower court's decision to require the prosecution to present evidence aft...continue reading

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