Facts:

The case of People of the Philippines vs. Diosdado de Guia (G.R. No. 59876) arose from a decision rendered by the Court of First Instance of Zambales, Branch 2, on April 5, 1982, where the accused, Diosdado de Guia, was found guilty of murder and sentenced to death. The incident occurred on July 21, 1981, in Barangay San Agustin, Iba, Zambales. The prosecution's evidence revealed that the victim, Narciso Gonzales, was attacked by de Guia while they were cleaning fish at the home of Nena Abrigo. Witnesses testified that de Guia entered the kitchen and began hacking Gonzales with a bolo, inflicting multiple severe injuries that ultimately led to Gonzales's death. The trial court's findings were based solely on the prosecution's evidence, as the defense did not present any witnesses or evidence. The trial court sentenced de Guia to death and ordered him to indemnify the victim's heirs. The accused later appealed, claiming that the trial court erred in accep...

Facts:

1. Incident Details:

   • On July 21, 1981, in Barangay San Agustin, Iba, Zambales, Diosdado de Guia attacked and hacked Narciso Gonzales with a bolo, causing multiple fatal injuries.
   • The injuries included hacking wounds to the head, neck, and back, leading to Narciso Gonzales' death due to hypovolemic shock.

2. Witness Testimonies:

   • Noel Montefalcon, a farmer, testified that he and Narciso Gonzales were cleaning fish in the kitchen of Nena Abrigo when Diosdado de Guia entered and began hacking Narciso. He witnessed the attack and fled when de Guia chased him.
   • Eudias Abrigo, a housekeeper, testified that she knew both the accused and the victim and confirmed that Narciso Gonzales was hacked to death by Diosdado de Guia. She also testified about the expenses incurred for the victim's funeral.

3. Medical Evidence:

   • Emma Valdez, a medical records clerk, presented the death certificate and medico-legal certificate of Narciso Gonzales, confirming the cause of death.

4. Plea Changes:

   • The accused, Diosdado de Guia, changed his plea four times during the trial:
     • Initially pleaded "not guilty" on September 7, 1981.
     • Changed to "guilty" on September 17, 1981.
     • Reverted to "not guilty" on November 9, 1981.
     • Finally pleaded "guilty" on January 11, 1982.

5. Trial Court Decision:

   • The trial court found Diosdado de Guia guilty of murder and sentenced him to death, ordering him to indemnify the heirs of Narciso Gonzales and pay for funeral expenses.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Improvident Plea:

   • A plea of guilty must be made with full understanding of its consequences, especially in capital offenses. The trial court must ensure that the accused comprehends the nature of the charges and the implications of admitting to qualifying circumstances like treachery and evident premeditation.

2. Proof of Qualifying Circumstances:

   • Qualifying circumstances such as treachery and evident premeditation must be proven beyond reasonable doubt. In this case, the evidence did not sufficiently establish that the accused deliberately chose a method of attack that ensured the victim's inability to defend himself or that the killing was premeditated.

3. Mitigating and Aggravating Circumstances:

   • The absence of qualifying circumstances reduces the crime from murder to homicide. The Court found no aggravating or mitigating circumstances present, leading to the imposition of a medium penalty for homicide.

4. Duty of Trial Courts:

   • Trial courts must exercise "extra-solicitous care" in ensuring that an accused who pleads guilty fully understands the nature and consequences of their plea, particularly in cases involving the death penalty.