Case Digest (G.R. No. 241257) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On July 10, 2009, an Information was filed before the Regional Trial Court (RTC) of Hilongos, Leyte, Branch 18, charging Brendo P. Pagal, a.k.a. “Dindo,” with murder under Article 248 of the Revised Penal Code. The crime was alleged to have occurred on December 15, 2008 in Brgy. Esperanza, Matalom, Leyte, when the accused, with intent to kill and employing treachery and superior strength, fatally stabbed his sister-in-law, Selma Pagal, in the back, penetrating her chest and causing her immediate death. At his arraignment on August 20, 2009, Pagal entered a plea of guilty. Pursuant to Section 3, Rule 116 of the 2000 Revised Rules of Criminal Procedure, which governs pleas of guilty to capital offenses, the RTC conducted a cursory inquiry into the voluntariness of his plea and ordered the prosecution to present evidence on four separate hearing dates (November 17, 2010; February 22, 2011; May 11, 2011; and July 20, 2011) to establish Pagal’s guilt and precise degree of culpability... Case Digest (G.R. No. 241257) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Antecedents
- On December 15, 2008, in Brgy. Esperanza, Matalom, Leyte, Brendo P. Pagal slashed Selma Pagal with a bolo, causing her death. He was charged with murder under Article 248 of the Revised Penal Code.
- An Information was filed July 10, 2009. At arraignment on August 20, 2009, Pagal pleaded guilty. The RTC found the plea voluntary and scheduled trial dates for the prosecution to prove guilt and degree of culpability.
- Failure of the prosecution to present evidence
- The RTC set four hearing dates (November 17, 2010; February 22, May 11, and July 20, 2011). Despite multiple subpoenas, no prosecution witness appeared.
- Both prosecution and defense moved for submission; on October 5, 2011, the RTC convicted Pagal of murder solely on his guilty plea and sentenced him to reclusion perpetua with indemnity and damages.
- Court of Appeals decision
- In CA-G.R. CR-HC No. 01521, May 8, 2018, the CA held that the RTC failed to conduct the mandatory searching inquiry under Section 3, Rule 116 of the Rules of Court and insufficiently proved guilt beyond reasonable doubt.
- The CA set aside the RTC conviction and remanded the case for full compliance with Section 3, Rule 116.
- Supreme Court proceedings
- On September 26, 2018, the SC en banc allowed supplemental briefs. Pagal urged acquittal for lack of proof. The OSG urged remand for full compliance with Section 3, Rule 116.
- On September 29, 2020, the Court en banc promulgated its decision.
Issues:
- Whether the trial court erred in accepting Pagal’s guilty plea to a capital offense without conducting a searching inquiry into its voluntariness and his comprehension of its consequences, in violation of Section 3, Rule 116.
- Whether the RTC could convict Pagal of murder solely on his guilty plea despite the prosecution’s failure to present any evidence proving guilt beyond reasonable doubt.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)