Case Digest (G.R. No. L-34674)
Case Digest (G.R. No. L-34674)
Facts:
The People of the Philippines v. Pablo Gonzales, G.R. No. L-34674, August 06, 1979, the Supreme Court En Banc, Per Curiam. The case arose from Criminal Case No. CCC-VII-883-Rizal in the Circuit Criminal Court of Rizal, where Pablo Gonzales (defendant-appellant) was charged in an information with murder for the April 9, 1971 killing of fellow inmate Moises Malines at the New Bilibid Prison, Muntinglupa, Rizal. The information alleged multiple stab wounds and that the killing was attended by the qualifying circumstance of treachery and the generic circumstance of evident premeditation.At arraignment on August 5, 1971, Gonzales, with court-appointed counsel, pleaded not guilty. At the scheduled trial the accused sought to withdraw that plea and substitute a plea of guilty; he was re-arraigned pursuant to Section 1, Rule 116 (in relation to Rule 118) of the New Rules of Court, was placed on the witness stand, and acknowledged that he understood the consequences of pleading guilty, including the penalty of death, and that his plea was voluntary. The trial judge nevertheless required the prosecution to present evidence under the doctrine established in People v. Epifanio Flores.
The prosecution presented inmate witnesses Cecilio de Leon and Brigildo Amon who described seeing Gonzales and companions enter the neuro-psycho ward with bladed weapons and leave shortly after with bloody weapons; they did not personally see the stabbing. Dr. Ernesto Brion identified the necropsy report showing 22 stab wounds, two fatal. Bureau of Prisons investigator Jesus Tumagan identified the weapon and an extrajudicial confession (Exhibit D) in which Gonzales admitted planning and participating in the killing to avenge a gangmate. Defense counsel objected to admission of the confession and reserved the right to present evidence and to move to dismiss but did not file the motion or present evidence.
On September 9, 1971, the Circuit Criminal Court of Rizal found Gonzales guilty of murder and sentenced him to death, ordered indemnity and damages. Gonzales appealed to the Supreme Court arguing among other things that the substituted plea of guilty was accepted precipitately and that the evidence did not support treachery and evident premeditation. The Supreme Court then resolved the appeal and rendered the present decision.
Issues:
- Was the trial court’s acceptance of the substituted plea of guilty valid given the capital nature of the offense?
- Did the evidence presented sustain the finding of the qualifying circumstance of treachery and the aggravating circumstance of evident premeditation?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)