Title
People vs. Ama y Perez
Case
G.R. No. L-14783
Decision Date
Apr 29, 1961
Three inmates, already serving sentences, stabbed a fellow prisoner to death in Bilibid Prison. One pleaded guilty, leading to a death sentence upheld by the Supreme Court due to quasi-recidivism.
murder
change of plea
death penalty

Case Summary (G.R. No. L-14783)

Factual Background

The information charged that on or about August 27, 1958, in the New Bilibid Prison, municipality of Muntinlupa, province of Rizal, the accused, conspiring and confederating together and armed with sharp-pointed instruments, attacked and stabbed one Almario Bautista and thereby inflicted wounds which caused his instantaneous death. The information further alleged that the accused were quasi-recidivist, having committed the felony while serving sentences after conviction by final judgment, and that the crime was committed in the presence of public authorities engaged in the discharge of their duties.

Trial Court Proceedings

At arraignment before the Court of First Instance of Rizal the accused initially pleaded not guilty and the case was set for hearing on November 25, 1958. On that date Ernesto de Jesus and Alejandro Ramos secured a postponement to seek reinvestigation. MARCIAL AMA Y PEREZ moved to withdraw his plea of not guilty and to plead guilty. After the information was read and explained to him and with the assistance of counsel de oficio, he pleaded guilty as charged. His counsel moved for imposition of the minimum penalty on account of the plea of guilty. The prosecution objected, asserting that the special aggravating circumstance of quasi-recidivism could not be offset by the mitigating circumstance of a plea of guilty and thus that the maximum penalty, death, was proper. The fiscal thereafter produced proof relative to the alleged aggravating circumstances, and the trial court sentenced MARCIAL AMA Y PEREZ to death, ordered indemnity of P6,000 to the heirs of the deceased, denied subsidiary imprisonment in case of insolvency, and awarded costs. The case was reviewed by the Court under Section 9, Rule 119, Rules of Court.

Issues Presented

The principal assignment of error was that the trial court erred in permitting MARCIAL AMA Y PEREZ to change his plea to guilty without informing him that such a plea could not offset the special aggravating circumstance of quasi-recidivism alleged in the information and thus would not avert imposition of the death penalty. Appellant further argued that his appointed counsel committed oversight in advising a guilty plea in the face of Article 160 of the Revised Penal Code, and that the conviction rested merely on the plea of guilty without adequate evidence in support of the aggravating circumstances.

The Parties' Contentions

Appellant contended that, had he known the plea would not prevent the imposition of death, he would have insisted on a trial despite slim chances of acquittal, and that counsel de oficio erred in advising a guilty plea without regard to quasi-recidivism under Article 160 of the Revised Penal Code. The prosecution contended that a plea of guilty constituted an admission of all material facts of the information and that a formal plea of guilty sustained conviction without necessity of further proof, citing prevailing authorities. The prosecution also pointed to the presence of appointed counsel at arraignment and to the fiscal’s production of evidence regarding aggravating circumstances.

Ruling of the Court

The Court affirmed the judgment of the lower court. It held that the duty of the trial court at arraignment was to inform the accused of the nature and cause of the charge so that he might comprehend it, as prescribed by Section 1(b), Rule 111, Rules of Court, and that the law did not impose upon the court a duty to advise the accused of the exact penalty that would be meted out should he plead guilty. The Court further held that the record showed that the lower court did more than the minimum: the information was read and explained and the fiscal was invited to produce evidence of the aggravating circumstances so that counsel could examine it. The Court found no evidence that counsel de oficio failed in his duty.

Legal Basis and Reasoning

The Court reiterated the settled rule that a plea of guilty is an admission of all material facts alleged in the complaint or information and that a formal plea of guilty is sufficient to sustain a conviction for the offense charged without necessity of additional proof, drawing on prior decisions including U.S. vs. Barba, U.S. vs. Santiago, People vs. Valencia, People vs. Palupe, People vs. Acosta, and People vs. Yamson and Romero. The Court observed that this rule applies even where the offense is capital because the admission covers both the crime and its attendant circumstances. The Court noted the presumption of regularity in the performance of official duties by appointed counsel and found nothing in the record to rebut that presumption. The Court also rejected the argument that a plea of guilty made the accused wor

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