Case Summary (G.R. No. 137296)
Charges and Initial Proceedings
On October 16, 1958, Marcial Ama y Perez was charged, along with Ernesto de Jesus and Alejandro Ramos, with the murder of Almario Bautista in the New Bilibid Prison. The information alleged that, on August 27, 1958, the accused, armed with weapons and acting in concert, attacked Bautista with treachery and evident premeditation. The charge emphasized the defendants' status as quasi-recidivists due to prior convictions and the seriousness of the crime committed in the presence of public authorities.
Change of Plea and Trial Court's Actions
Upon arraignment, the defendants initially pleaded not guilty. However, on November 25, 1958, Marcial Ama y Perez sought to change his plea to guilty. The trial court granted this request after ensuring Ama y Perez understood the charges through a thorough reading and explanation of the information. The court then permitted a hearing on the case where prosecution introduced evidence regarding aggravating circumstances under the information. Ama y Perez, ultimately pleading guilty, was sentenced to death and ordered to indemnify the heirs of the deceased.
Assignment of Errors and Legal Arguments
On appeal, the defense argued that the trial court erred in allowing the change of plea without fully informing Ama y Perez that his guilty plea would not mitigate the death penalty in light of the aggravating circumstance of quasi-recidivism. The defense contended that had Ama y Perez been aware of this, he would have opted to go to trial instead. They also claimed the appointed counsel's oversight constituted ineffective assistance as it did not adequately address the implications of the plea.
Court's Ruling on Appeal
The appellate court found no merit in the appeal. It stated that the primary obligation of the court was to inform Ama y Perez of the nature of the charge, which it fulfilled. The court determined that Ama y Perez, assisted by counsel, must have comprehended the gravity of his plea. The legal principle established in prior rulings was reiterated, clarifying that a plea of guilty serves as an admission of all material facts and sufficient to sustain a conviction without the necessity of add
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Case Overview
- Date of Decision: April 29, 1961
- Court: Supreme Court of the Philippines
- Case Reference: 111 Phil. 882, G.R. No. L-14783
- Parties Involved: The People of the Philippines (Plaintiff and Appellee) vs. Marcial Ama y Perez et al. (Defendants)
Background of the Case
- On October 16, 1958, Marcial Ama y Perez, Ernesto de Jesus, and Alejandro Ramos were charged with murder in the Court of First Instance of Rizal.
- The information charged that on August 27, 1958, in New Bilibid Prison, the accused conspired and attacked Almario Bautista with deadly weapons, resulting in his instantaneous death.
- The accused were classified as quasi-recidivists, having committed the crime while serving sentences for prior convictions.
Procedural History
- The accused pleaded not guilty at arraignment.
- A hearing was scheduled for November 25, 1958, but De Jesus and Ramos requested a postponement for reinvestigation.
- Marcial Ama y Perez sought to change his plea from not guilty to guilty, which was granted by the court.
Admission of Guilt and Sentencing
- Upon granting the plea change, the court requested the information to be read and explained to Ama, who then voluntarily pleaded guilty with legal counsel present.
- The defense counsel requested the imposition of the minimum penalty due to the guilty plea, while the