G.R. No. L-58678-80 - People vs. Mendoza

Andy de los Santos, Jr. was charged with estafa for issuing postdated checks in November 1980 as payment for lumber purchases from Rafael Ayuste.
The checks, drawn against the Quezon City branch of the Pacific Banking Corporation for amounts of P33,785.80, P30,877.40, and P31,920.60, were dishonored for lack of funds.
The charges were formally filed on July 29, 1981, with three separate informations (Criminal Cases Nos. 749, 753, and 754) all dated May 28, 1981.

At arraignment on August 12, 1981, de los Santos pleaded not guilty.
On September 7, 1981, during a hearing, his counsel de oficio informed the court that de los Santos wished to withdraw his plea of not guilty and substitute it with a plea of guilty.

The accused confirmed that he understood the consequences, including the imposition of imprisonment sentences, and that his plea was made voluntarily after consultation with his lawyer.
His counsel highlighted mitigating circumstances such as the plea of guilty and his voluntary surrender, which the fiscal did not oppose.

The trial court rendered three separate decisions on the same day (September 7, 1981), imposing indeterminate penalties and credit for preventive imprisonment, noting that de los Santos received the benefit of two extenuating circumstances.

On September 10, 1981, de los Santos’ counsel filed a “petition” (motion) to set aside the judgments of conviction and to substitute the plea of guilty with that of not guilty pursuant to Section 6, Rule 118 of the Rules of Court.

The petition stated the accused’s intention to withdraw his plea of guilty and seek a trial on the merits.

The trial court, in its order dated September 14, 1981, set aside the judgments of conviction, allowed the substitution of plea to not guilty, and scheduled trial for September 21, 1981.
The fiscal subsequently filed motions for reconsideration on September 17 and again on September 23, focusing on alleged errors in the computation of the penalties and the baseless grounds of the petition.
On October 5, 1981, after the prosecution failed to present its evidence and upon invocation of the accused’s right to a speedy trial, the trial court dismissed the estafa cases and ordered de los Santos’ release.

The People of the Philippines challenged the trial court’s orders based on the contention that the withdrawal of the plea of guilty and the setting aside of the judgment of conviction were improper.

It was argued that the petition lacked any rational or meritorious explanation, amounting merely to a whimsical change of mind.

The central legal issue arose as to whether the trial court had gravely abused its discretion and acted without jurisdiction in permitting the withdrawal of a voluntary and informed plea of guilty.

Whether the trial court gravely abused its discretion by setting aside the judgments of conviction based solely on the accused’s unsubstantiated petition to withdraw his plea of guilty and substitute it with a plea of not guilty.
Whether the accused’s petition, lacking evidence of error, fraud, duress, or any misrepresentation, provided sufficient ground for reopening the case and altering his plea under Section 6, Rule 118 of the Rules of Court.
Whether the trial court’s actions amounted to a reopening of the case and a disregard for the solemnity of the judicial proceeding in handling a plea of guilt.