Prosecution's burden of proof when accused pleads guilty

On account of the amendment of the 1964 Rules of the Court, the second duty of the trial court, to require the prosecution to present evidence of the guilt of the accused beyond reasonable doubt, has become mandatory. Hence, it is imperative that the trial court requires the presentation of evidence from the prosecution to enable itself to determine the precise participation and the degree of culpability of the accused in the perpetration of the capital offense charged.[74]

The reason behind this requirement is that the plea of guilt alone can never be sufficient to produce guilt beyond reasonable doubt. It must be remembered that a plea of guilty is only a supporting evidence or secondary basis for a finding of culpability, the main proof being the evidence presented by the prosecution to prove the accused's guilt beyond reasonable doubt. Once an accused charged with a capital offense enters a plea of guilty, a regular trial shall be conducted just the same as if no such plea was entered. The court cannot, and should not, relieve the prosecution of its duty to prove the guilt of the accused and the precise degree of his culpability by the requisite quantum of evidence. The reason for such rule is to preclude any room for reasonable doubt in the mind of the trial court, or the Supreme Court on review, as to the possibility that the accused might have misunderstood the nature of the charge to which he pleaded guilty, and to ascertain the circumstances attendant to the commission of the crime which may justify or require either a greater or lesser degree of severity in the imposition of the prescribed penalties.[75]

Thus, as it stands, the conviction of the accused no longer depends solely on his plea of guilty but rather on the strength of the prosecution's evidence.

https://www.projectjurisprudence.com/2021/08/gr-no-241257-september-29-2020.html