3 requisites when accused pleads guilty to a capital offense
In U.S. v. Burlado,[48] this Court affirmed therein accused's
conviction for the crime of qualified theft on the strength of his plea of
guilty. The Court explained that "[a] plea of guilty, when formally entered on
arraignment, is sufficient to sustain a conviction of any offense charged in
the information without the introduction of further evidence, the defendant
himself having supplied the necessary proof by his plea of guilty. (United
States v. Dineros, 18 Phil. 566 (1911); United States v. Jamad, 37 Phil.
305 (1917).) The defendant having admitted his guilt of the facts charged in the
complaint, the only question left for decision is the penalty"[49]
The 1940 Rules of Court, the earliest progenitor of the 2000
Revised Rules, extended the same level of protection. Sec. 5, Rule 114 of the
1940 Rules of Court reads:
SECTION 5. Plea of Guilty — Determination of Punishment. — Where the defendant pleads guilty to a complaint or information, if the court accepts the plea and has discretion as to the punishment for the offense, it may hear witnesses to determine what punishment shall be imposed.[50]
The 1964 version of the Rules of Court reproduced this
section verbatim.[51] Thus, when an accused pleads guilty to a
capital offense, the court may hear witnesses for purposes of determining the
punishment to be imposed; the guilt of the accused was a forgone conclusion.
The rule seemed to institutionalize Jamad as shown by the discretionary nature
of the hearing.
Accordingly, in People v. Ng
Pek,[52] this Court stated that "[t]he record shows that when the case
was called for the arraignment of the accused on November 3, 1947, the accused
waived his right to be assisted by counsel and then and there entered the plea
of guilty. That plea necessarily foreclosed the right of the accused to defend himself
and left the court with no other alternative than to impose the penalty
prescribed by law."[53]
In the same breath, the Court, in People v. Santa
Rosa,[54] upheld the conviction of therein accused for illegal possession
of a firearm due to his plea of guilty. It stated that "[t]he general rule is
that 'a plea of guilty when formally entered on arraignment is sufficient to
sustain a conviction of any offense charged in the information without the
introduction of further evidence, the defendant himself having supplied the
necessary proof by his plea of guilty."[55]
Finally, in People
v. Acosta,[56] which involved the imposition of the supreme penalty of
death for the crime of robbery with homicide, this Court upheld the conviction
and penalty imposed and stated that:
"x x x the essence of the plea of guilty in a criminal trial is that the accused, on arraignment, admits his guilt freely, voluntarily and with full knowledge of the consequences and meaning of his act, and with a clear understanding of the precise nature of the crime charged in the information; that when formally entered, such a plea is sufficient to sustain a conviction of any offense charged in the information, even a capital offense, without the introduction of further evidence, the defendant having himself supplied the necessary proof; and that while it may be prudent and advisable in some cases, especially where grave crimes are charged, to take additional evidence as to the guilt of the accused and the circumstances attendant upon the commission of the crime nevertheless it lies in the sound discretion of the court whether to take evidence or not in any case where it is satisfied that the plea of guilty has been entered by the accused with full knowledge of the meaning and consequences of his act. (citations omitted)"[57]
Clearly, to this point, the reception of evidence when an accused pleads
guilty depended on the sound discretion of the trial court.
However,
the 1985 Rules on Criminal Procedure (1985 Rules) introduced a paradigm shift
to the formerly discretionary role of trial courts when an accused pleads
guilty to a capital offense. The 1985 version of the rule,[58] as
amended, reads:
SECTION 3. Plea of Guilty to Capital Offense; Reception of Evidence. — When the accused pleads guilty to a capital offense, the court shall conduct a searching inquiry into the voluntariness and full comprehension of the consequences of his plea and require the prosecution to prove his guilt and the precise degree of culpability. The accused may also present evidence in his behalf. (5a, R-118)
The 2000 Revised Rules retained the salient points of the 1985 amendment.
Hence, at present, the three (3)-fold duty of the trial court in instances
where the accused pleads guilty to a capital offense is as follows: (1)
conduct a searching inquiry, (2) require the prosecution to prove the
accused's guilt and precise degree of culpability, and (3) allow the accused
to present evidence on his behalf.
The present rules formalized the
requirement of the conduct of a searching inquiry as to the accused's
voluntariness and full comprehension of the consequences of his plea. Further,
it made mandatory the reception of evidence in cases where the accused pleads
guilty to a capital offense. Most importantly, the present rules require that
the prosecution prove beyond reasonable doubt the guilt of the accused.
Evidently, starting with the 1985 Rules, the accused may no longer be
convicted for a capital offense on the sole basis of his plea of guilty.
The
Court acknowledged the paradigm shift in People v.
Lagarto,[59] thus:
Section 5, Rule 118 of the old Rules of Court provides that "Where the defendant pleads guilty to a complaint or information, if the trial court accepts the plea and has discretion as to the punishment for the offense, it may hear witnesses to determine what punishments shall be imposed." The trial court in a criminal case may sentence a defendant who pleads guilty to the offense charged in the information, without the necessity of taking testimony. (US v. Talbanos, 6 Phil. 541). Yet, it is advisable for the trial court to call witnesses for the purpose of establishing the guilt and the degree of culpability of the defendant. (People vs. Comendador, supra) The present Revised Rules of Court, however, decrees that where the accused pleads guilty to a capital offense, it is now mandatory for the court to require the prosecution to prove the guilt of the accused and his precise degree of culpability, with the accused being likewise entitled to present evidence to prove, inter alia, mitigating circumstances (See People vs. Camay, 152 SCRA 401; Section 3, Rule 116 of Rules of Court).[60] (emphasis supplied)
It is equally important to note that the 1985 Rules retained the directive
that the reception of evidence in cases where the accused pleads guilty to a
non-capital offense is discretionary on the part of the trial court.
This
is encapsulated in Sec. 4, Rule 116 of the 1985 Rules.[61] The 2000
Revised Rules adopted Sec. 4, Rule 116 of the 1985 Rules verbatim.
Considering
the mandatory nature of Sec. 3, Rule 116 of the 2000 Revised Rules, this
Court, in People v. Gambao (Gambao),[62] restated the duties of the
trial court when the accused pleads guilty to a capital offense as follows:
(1) to conduct a searching inquiry into the voluntariness and full comprehension of the consequences of the plea of guilt,
(2) to require the prosecution to still prove the guilt of the accused and the precise degree of his culpability, and
(3) to inquire whether or not the accused wishes to present evidence in his behalf and allow him to do so if he desires.[63]
Gambao also explained the rationale for these duties, thus:
Courts must proceed with more care where the possible punishment is in its severest form, namely death, for the reason that the execution of such a sentence is irreversible. The primordial purpose is to avoid improvident pleas of guilt on the part of an accused where grave crimes are involved since he might be admitting his guilt before the court and thus forfeiting his life and liberty without having fully understood the meaning, significance and consequence of his plea. Moreover, the requirement of taking further evidence would aid this Court on appellate review in determining the propriety or impropriety of the plea.[64] (emphasis supplied)
[48] 42 Phil. 72(1921).
[49] Id. at 74. (emphasis supplied)
[50] 1940 RULES OF COURT, Rule 114. The provision was lifted from Section 229, Criminal Proc. Of the American Law Institute, per Moran, Comments on the Rules of Court, Rev. Ed. 1952, Vol. II, p. 829.
[51] 1964 RULES OF COURT, Rule 118, Sec. 5.
[52] 81 Phil. 562 (1948).
[53] Id. at 563.
[54] 88 Phil. 487 (1951).
[55] Id. at 489. (emphasis supplied)
[56] 98 Phil. 642 (1956).
[57] Id. at 644-645.
[58] 1985 RULES ON CRIMINAL PROCEDURE, Rule 116.
[59] 274 Phil. 11 (1991).
[60] Id. at 18-19.
[61] SECTION 4. Plea of Guilty to Non-Capital Offense; Reception of Evidence, Discretionary. — When the accused pleads guilty to a non-capital offense, the court may receive evidence from the parties to determine the penalty to be imposed. (5a, R-118)
[62] 718 Phil. 507 (2013).
[63] Id. at 520-521.
[64] Id. at 521.