Case Digest (G.R. No. 241257)
Facts:
People of the Philippines v. Brendo P. Pagal, G.R. No. 241257, September 29, 2020, the Supreme Court En Banc, Gesmundo, J., writing for the Court.The prosecution (the People of the Philippines) filed an Information dated July 10, 2009 charging Brendo P. Pagal (accused‑appellant) with murder arising from the December 15, 2008 death of Selma Pagal in Matalom, Leyte. At arraignment on August 20, 2009 accused‑appellant pleaded “guilty” to the capital offense. The Regional Trial Court (RTC), Branch 18, Hilongos, Leyte, accepted the plea, recognized its duty under Section 3, Rule 116 to conduct a searching inquiry and to require the prosecution to prove guilt and degree of culpability, and ordered the prosecution to present evidence to determine culpability and penalty.
The RTC set multiple hearing dates and issued repeat subpoenas for prosecution witnesses (Angelito Pagal, Cesar Jarden, Jaimelito/Emelita Calupas and Dr. Radegunda Uy). Despite service, none of the prosecution witnesses appeared to testify on the scheduled dates (November 17, 2010; February 22, 2011; May 11, 2011; July 20, 2011). The prosecution and defense eventually moved to submit the case for decision. On October 5, 2011 the RTC rendered an order finding accused‑appellant guilty and sentencing him to reclusion perpetua, awarding civil indemnity and moral damages; the dispositive paragraph did not explicitly identify the felony for which conviction was imposed.
Accused‑appellant appealed to the Court of Appeals (CA). The CA, in a Decision promulgated May 8, 2018 (CA‑G.R. CR‑HC No. 01521), annulled and set aside the RTC Order and remanded the case to the RTC for compliance with Section 3, Rule 116 (a searching inquiry and reception of evidence), because the RTC had not shown a proper searching inquiry and the prosecution had presented no evidence to sustain a conviction independent of the plea.
Accused‑appellant sought relief in the Supreme Court by filing a notice of appeal under Sec. 13(c), Rule 124; the Court observed that the procedural vehicle wa...(Subscriber-Only)
Issues:
- Was the appeal before the Supreme Court properly brought by notice of appeal under Sec. 13(c), Rule 124, or should it have been by petition for review on certiorari under Rule 45?
- Did the RTC comply with Section 3, Rule 116 (the searching‑inquiry requirement and the duty to require the prosecution to prove guilt and degree of culpability) before convicting accused‑appellant on his plea of guilty?
- Where an accused pleads guilty to a capital offense but the prosecution, after being afforded multiple opportunities, presents no evidence, is the proper remedy remand for re‑arraignment and reception of evidence or outright acquittal?
- Would remanding the case for re‑trial unduly prejudice accused‑appellant in light of his lengthy prevent...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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