G.R. No. 159699 - Acance vs. Court of Appeals

The case involves an accused, Rolando Camay, who pleaded guilty to the capital offense of robbery with homicide.
The plea was governed by the provisions in the Rules on Criminal Procedure:

The new formulation under Section 3, Rule 116 (effective January 1, 1985) requires a searching inquiry into the voluntariness and full comprehension of the plea, an order to the prosecution to prove guilt and the precise degree of culpability, and permits the accused to offer evidence.
The older rule, found in Section 5, Rule 118, is more succinct but essentially mandates that, after a plea of guilty, the court may hear witnesses to determine the punishment if this is within its discretion.

Jurisprudential guidance has long stressed that even when a plea of guilty is accepted, establishing that the defendant understands the charges and consequences is crucial, especially where the death penalty is involved.

The accused, with assistance from counsel de oficio, was fully informed of the nature of the charge and the grave consequences involved.
Specific questions were posed to ensure that the accused knew he was pleading guilty to robbery with homicide and fully understood the possibility of the death penalty by electric chair.
The accused affirmed his understanding of the charges and the severe penalty.

The accused’s voluntary and informed plea was thereby established after these rigorous inquiries.

Angelita Madianda, the victim’s daughter, who recounted the incident where the accused barged into her home, demanded money, and inflicted violence.
Pilosopo Madianda, the victim’s husband, who testified regarding the discovery of his deceased wife and noted the missing amount from their trunk.
Juan Lanquibo, who identified the Death Certificate of the deceased, Enriquita Madianda.
Judge Manuel B. Castro testified about the accused’s confession, including matters related to the accused’s signed and sworn Affidavit of Confession.

The accused, by way of his counsel de oficio, opted not to present any evidence in his own behalf, maintaining his plea throughout.

The trial court rendered a verdict of guilty in a decision dated May 2, 1979, promulgated on June 5, 1979.
The sentence imposed included:

The extreme penalty of death.
An indemnity for the heirs of the deceased set at P12,000.00, along with the recovery of P600.00 deemed stolen.
Payment of court costs.

The counsel de oficio filed a “Memorandum In Lieu Of Appellant’s Brief.”
The Solicitor General filed a “Manifestation and Motion In Lieu Of Appellee’s Brief.”

Both pleadings stressed that the trial court’s proceedings were in line with existing law and evidentiary requirements.

Whether the trial court properly conducted a searching inquiry into the voluntariness and full comprehension of the accused’s plea of guilty.
Whether the court properly required the prosecution to present evidence to establish both the guilt of the accused and the precise degree of his culpability, despite the guilty plea.

Whether the evidence presented by the prosecution was sufficiently corroborative and substantial to support a conviction for a capital offense.
Whether the trial court’s discretion in determining the necessity of additional evidence (post-plea) was exercised properly.

Whether imposing the death penalty was appropriate given the circumstances and evidentiary findings.
Whether the subsequent reduction of the penalty to reclusion perpetua and modifications to indemnity were justified by the evidence and legal standards applied.