Facts:

• Roberto Bernas y Nacario was charged with multiple counts of rape against his daughters, Evelyn and Mary Jane.
• The incidents occurred in Barangay Tible, Sipocot, Camarines Sur, Philippines.
• The first incident involving Evelyn, aged 13, was reported on July 1, 1996.
• The second and third incidents involved Mary Jane, aged 15, occurring on May 7 and June 10, 1996.
• The Regional Trial Court (RTC) of Libmanan convicted Bernas on February 27, 1998, sentencing him to death.
• The conviction was based on victim testimonies and medical evidence confirming sexual abuse.
• Initially pleading not guilty, Bernas later changed his plea to guilty for two counts of rape against Mary Jane, while being acquitted of other charges.
• The case was automatically reviewed by the Supreme Court due to the death penalty.

Issue:

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Ruling:

• The Supreme Court ruled in favor of the appellant, stating that the trial court erred in accepting his guilty pleas without proper inquiry.
• The decisions of the RTC...(Unlock)

Ratio:

• The Supreme Court emphasized the necessity of a searching inquiry when an accused pleads guilty to a capital offense to ensure the plea is made voluntarily and with full understanding.
• The trial court failed to adequately assess the voluntariness of Bernas's plea and did not ensure he understood the implications of changing his plea.
• The inquiry conducted by the trial judge was insufficient, lacking a thorough examination of the defense counsel's explanation regarding the plea's conseq...continue reading