People Vs Pagal

PEOPLE VS.
PAGAL
G.R. No. 241257, September 29, 2020
SYPNOSIS:
During his arraignment on August 20, 2009, accused-appellant pleaded "guilty"

to the crime of murder. The RTC found the plea to be voluntary and with full
understanding of its consequences. Thus, it directed the prosecution to present
evidence to prove the guilt of accused-appellant and to determine the exact degree of
his culpability in accordance with Section 3, Rule 116 of the 2000 Revised Rules of
Criminal Procedure (2000 Revised Rules). However, the prosecution failed to present
its witnesses despite due notice. Hence, the trial court found accused-appellant guilty
beyond reasonable doubt based solely on his plea of guilty. It stated that accused-
appellant maintained his plea despite being apprised that he will be sentenced and
imprisoned on the basis thereof.
PRINCIPLES:
Jamad guidelines:
(1) 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 or crimes charged in the complaint or information.
(2) Such a plea of guilty, when formally entered on arraignment, 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.
(3) There is nothing in the law in this jurisdiction which forbids the introduction of
evidence as to the guilt of the accused, and the circumstances attendant upon the
commission of the crime, after the entry of a plea of "guilty."
(4) Having in mind the danger of the entry of improvident pleas of "guilty" in
criminal cases, the prudent and advisable course, especially in cases wherein grave
crimes are charged, is to take additional evidence as to the guilt of the accused and the
circumstances attendant upon the commission of the crime.
(5) The better practice would indicate that, when practicable, such additional
evidence should be sufficient to sustain a judgment of conviction independently of the
plea of guilty, or at least to leave no room for reasonable doubt in the mind of either the
trial or the appellate court as to the possibility of a misunderstanding on the part of the
accused as to the precise nature of the charges to which he pleaded guilty.
(6) Notwithstanding what has been said, it lies in the sound judicial discretion of
the trial judge whether he will take evidence or not in any case wherein he is satisfied
that a plea of "guilty" has been entered by the accused, with full knowledge of the
meaning and consequences of his act.
(7) But in the event that no evidence is taken, this court, if called upon to review
the proceedings had in the court below, may reverse and send back for a new trial, if,
on the whole record, a reasonable doubt arises as to whether the accused did in fact
enter the plea of "guilty" with full knowledge of the meaning and consequences of the
act.
Three (3)-fold duty of the trial court in instances where the accused pleads guilty to a
capital offense is as follows:
A. Conduct a searching inquiry.
"searching inquiry" when an accused pleads guilty, particularly —
1. The trial court shall hear both the prosecution and the accused with their
respective counsel on the desire or manifestation of the accused to waive the right to
present evidence and be heard.
2. The trial court shall ensure the attendance of the prosecution and especially
the accused with their respective counsel in the hearing which must be recorded. Their
presence must be duly entered in the minutes of the proceedings.
3. During the hearing, it shall be the task of the trial court to —
a. ask the defense counsel a series of question to determine whether he

had conferred with and completely explained to the accused that he had the right
to present evidence and be heard as well as its meaning and consequences,
together with the significance and outcome of the waiver of such right. If the
lawyer for the accused has not done so, the trial court shall give the latter enough
time to fulfill this professional obligation.
b. inquire from the defense counsel with conformity of the accused

whether he wants to present evidence or submit a memorandum elucidating on
the contradictions and insufficiency of the prosecution evidence, if any, or in
default theory, file a demurrer to evidence with prior leave of court, if he so
believes that the prosecution evidence is so weak that it need not even be
rebutted. If there is a desire to do so, the trial court shall give the defense enough
time to this purpose.
c. elicit information about the personality profile of the accused, such as

his age, socio-economic status, and educational background, which may serve
as a trustworthy index of his capacity to give a free and informed waiver.
d. all questions posed to the accused should be in a language known and
understood by the latter, hence, the record must state the language used for this
purpose as well as reflect the corresponding translation thereof in English.
B. Require the prosecution to prove the accused's guilt and precise degree of
culpability.
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.
C. Allow the accused to present evidence on his behalf.
The third duty imposed on the trial court by the 2000 Revised Rules is to
allow the accused to present exculpatory or mitigating evidence on his behalf in
order to properly calibrate the correct imposable penalty. This duty, however,
does not mean that the trial court can compel the accused to present evidence.
Of course, the court cannot force the accused to present evidence when there is
none. The accused is free to waive his right to present evidence if he so desires.

People Vs Pagal

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PEOPLE VS.

During his arraignment on August 20, 2009, accused-appellant pleaded "guilty"

(2) Such a plea of guilty, when formally entered on arraignment, is sufficient to

A. Conduct a searching inquiry.

"searching inquiry" when an accused pleads guilty, particularly —

3. During the hearing, it shall be the task of the trial court to —

a. ask the defense counsel a series of question to determine whether he

b. inquire from the defense counsel with conformity of the accused

c. elicit information about the personality profile of the accused, such as

Plea of guilt alone can never be sufficient to produce guilt beyond

C. Allow the accused to present evidence on his behalf.

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