Case Summary (G.R. No. L-34674)
Charge and Arraignment
Pablo Gonzales was charged with murder for fatally attacking fellow inmate Moises Malines at the New Bilibid Prison. The information alleged that Gonzales, armed with an improvised weapon, assaulted Malines, who was unarmed and unable to defend himself, resulting in his instantaneous death. The qualifying circumstances of treachery and evident premeditation preceded the charge. Initially pleading not guilty on August 5, 1971, Gonzales later withdrew this plea in favor of a guilty plea after consulting with his counsel on August 10, 1971.
Court Proceedings
The court conducted a re-arraignment following Gonzales' request to change his plea. During this proceeding, Gonzales acknowledged his understanding of the implications of his plea and the possibility of receiving the death penalty. The prosecution presented several witnesses, including fellow inmates who observed the events leading to Malines' death and medical experts who testified regarding the nature and extent of the injuries inflicted upon Malines. Gonzales' extrajudicial confession also played a crucial role in the prosecution's case, in which he admitted to participating in the attack to avenge a gang member's death.
Defense Claims
Gonzales' counsel raised objections regarding the admissibility of the extrajudicial confession, claiming it was obtained under duress. Additionally, he requested the opportunity to file a motion to dismiss, which ultimately was not pursued. The defense’s argument centered around the contention that the trial court failed to sufficiently ensure that Gonzales understood the implications of his plea of guilty.
Legal Standards on Guilty Pleas
The court emphasized the necessity for thorough proceedings when accepting guilty pleas, especially in capital cases. The trial court must ascertain that the defendant comprehends the charges and the potential penalties before accepting a plea. In this instance, the court satisfied itself regarding Gonzales' understanding and ensured that evidence corroborating his guilt and the degree of culpability was presented.
Findings on Treachery and Premeditation
The court found sufficient evidence to support the claim of treachery, reasoning that Gonzales and his accomplices initiated a surprise attack on Malines as soon as they gained entry to the ward. The suddenness of their actions, coupled with the number of inflicted wounds, suggested premeditated intent, as they had plotted the murder prior to its ex
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Case Overview
- Court: Supreme Court of the Philippines
- Date of Decision: August 06, 1979
- G.R. No.: L-34674
- Parties: The People of the Philippines (Plaintiff-Appellee) vs. Pablo Gonzales (Defendant-Appellant)
- Nature of Case: Criminal Case No. CCC-VII-883-Rizal for the crime of Murder
Facts of the Case
- The accused, Pablo Gonzales, was charged with murder following an incident on April 9, 1971, at the New Bilibid Prison, Muntinglupa, Rizal.
- The information filed against Gonzales alleged that he used an improvised deadly weapon to assault Moises Malines, also a prisoner, resulting in Malines' death due to multiple stab wounds.
- The charge included qualifying circumstances of treachery and evident premeditation.
Arraignment and Plea
- Gonzales was arraigned on August 5, 1971, and initially pleaded not guilty.
- During the trial scheduled for August 10, 1971, he expressed a desire to withdraw his plea and substitute it with a plea of guilty.
- The court conducted a re-arraignment, wherein Gonzales confirmed his plea of guilty after being questioned on the implications of his plea, including the possibility of receiving the death penalty.
Court Proceedings
- Following the guilty plea, the court required evidence to be presented to establish the guilt and culpability of Gonzales, adhering to the precedent set in the case of People vs. Epifanio Fl