Case Digest (G.R. No. L-66945)
Case Digest (G.R. No. L-66945)
Facts:
People of the Philippines v. Eduardo Bandojo and Mamerto Artuz, G.R. No. 66945, July 09, 1986, the Supreme Court En Banc, Cruz, J., writing for the Court.The Information charged the two accused-appellants with piracy in violation of P.D. 532 for acts committed on June 15, 1983 aboard a pumpboat in the waters of Bantayan, Cebu: the fatal shooting of Consolacion Alfar, the taking of P5,000 from her, disposal of the body at sea, and forcing other passengers overboard. The accused made extrajudicial confessions on June 17, 1983; these confessions were taken without observance of their rights under Article IV, Section 20 of the Constitution and were rejected by the Court as inadmissible.
At formal arraignment the accused separately pleaded guilty. The trial judge did not immediately sentence; instead he conducted extensive, searching examinations of both accused on February 3, 1984, and again on February 10, 1984, to ascertain they understood the nature and consequences of their pleas. During these courtroom interrogations the accused gave inconsistent statements: each at different times blamed the other for the killing and minimized his own role, but both consistently admitted the robbery and affirmed guilty pleas while seeking mercy or a lesser penalty. At arrest, money taken (minus P100) was found in their possession.
The trial court accepted the pleas, convicted the accused and imposed the death penalty based on the guilty pleas. The case reached the Supreme Court by direct appeal. The Court reviewed whether the guilty pleas were validly entered and properly accepted and whether the trial court should have required the reception of independent evidence in a capital case.
Issues:
- Were the guilty pleas of the accused-appellants validly entered and properly accepted by the trial court?
- In a capital case where the accused pleads guilty but later gives testimony inconsistent with the plea, must the trial court always receive independent testimony/evidence to establish guilt before imposing the capital penalty?
- On the record presented, was the guilt of the accused-appellants for piracy established?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)