Case Summary (G.R. No. 241257)
Prosecution’s Burden and Trial Court Lapse
Even following a plea of guilty to a capital crime, the prosecution must still prove guilt and precise culpability. Although accused-appellant entered a plea, the court scheduled four hearings for prosecution evidence. No witnesses appeared despite duly issued subpoenas. The court neither inquired into reasons for their absence nor compelled attendance, and instead accepted the plea’s sufficiency.
Effect of Improvident Guilty Plea
Because the court failed its searching inquiry duties, accused-appellant’s plea was improvident and void. An improvident plea taints the integrity of subsequent proceedings and precludes a valid judgment without further proof of guilt beyond reasonable doubt.
Requirement of Evidence Despite Guilty Plea
Jurisprudence mandates admission of evidence after guilty pleas in capital offenses to guard against wrongful admissions. The prosecution may not rest on a plea alone; it must present evidence sufficient for conviction independent of the plea. Where evidence is wholly absent, conviction based solely on the plea is unconstitutional.
Remedial Approaches: Remand or Acquittal
Traditionally, convictions based only on an improvident plea are set aside and cases remanded for re-arraignment and presentation of evidence. Remand is warranted where trial unfairness or prejudice arises from the plea, or where the prosecution is deprived of proof opportunities. Only if the prosecution truly cannot adduce proof after reasonable chance does acquittal become proper.
Proposed Guidelines for Plea Procedure
To prevent recurrence, courts should codify clear procedures: (1) full, recorded searching inquiry at arraignment; (2) mandatory prosecution evidence presentation; (3) accused’s option to present mitigating or exculpatory testimony; (4) use of bench warrants
...continue readingCase Syllabus (G.R. No. 241257)
Case Caption and Procedural Posture
- G.R. No. 241257 decided en banc on September 29, 2020
- RTC Hilongos, Leyte (Branch 18) October 5, 2011 Order convicting accused-appellant of murder (Reclusion perpetua)
- CA in CA-G.R. CR-HC No. 01521 May 8, 2018 Decision annulling RTC conviction and remanding for further proceedings
- Accused-appellant appealed to the Supreme Court by notice of appeal; parties adopted their CA briefs
Facts of the Case
- On or about December 15, 2008, Brgy. Esperanza, Matalom, Leyte: accused-appellant allegedly stabbed his sister-in-law, Selma Pagal, in the back, penetrating her chest and causing her death
- Private complainant (Angelito Pagal) and several relatives witnessed or learned of the attack
- Accused-appellant was indicted for murder under Article 248 of the Revised Penal Code
Indictment and Arraignment
- Information dated July 10, 2009 charged accused-appellant with murder
- Arraignment on August 20, 2009: accused-appellant pleaded “guilty” to the capital offense
- RTC found plea voluntary and fully comprehended; under Section 3, Rule 116, directed prosecution to present evidence to prove guilt and precise degree of culpability
Post-Plea Proceedings and Subpoenas
- Four hearing dates set for prosecution to present evidence: May 5, 2010; November 17, 2010; February 22, 2011; May 11, 2011; July 20, 2011
- RTC issued repeated subpoenas to Angelito Pagal, Cesar Jarden, Jaimelito Calupas, and Dr. Radegunda Uy—duly served—but none appeared at hearings
- Prosecution and defense jointly moved to submit case for decision after witnesses failed to testify
RTC Decision (October 5, 2011)
- Convicted accused-appellant of murder solely on his plea of guilty, citin