FACTS:

Rolly Albert y Oliver was convicted of murder and sentenced to reclusion perpetua. Throughout the proceedings, different judges handled the case, and the appellant was represented by different counsel de oficio. The appellant, who worked as a helper in a bakery, stabbed and killed Alfonso Quimen and wounded Marcelino Mendoza and Lito Ladao. He was also charged with frustrated homicide for the assault against Marcelino Mendoza. The appellant initially pleaded not guilty but later entered a guilty plea to a lesser offense. The trial court directed his confinement at the National Center for Mental Health due to signs of mental illness. After evaluation and treatment, appellant was discharged and recommitted to jail. Finally, he testified and admitted his participation in the killing of Alfonso Quimen.

The appellant, Rolly Albert, was charged with murder, a capital offense at the time. Appellant's counsel initially entered a plea of not guilty but later moved to withdraw the plea and record a plea of guilty. The trial court allowed the withdrawal and conducted a re-arraignment in Tagalog. The trial court also called appellant back to the witness stand to determine the degree of his culpability and his understanding of the guilty plea. The appellant now appeals his conviction, arguing that the trial court failed to ensure his understanding of the plea, allowed the change of plea, and convicted him despite the improvidence of his guilty plea.

This case involves the application of Section 3, Rule 116 of the 1985 Rules on Criminal Procedure, which mandates a searching inquiry into the voluntariness and full consequences of a guilty plea to a capital offense. The purpose is to prevent improvident pleas of guilt, particularly in grave crimes where innocent persons have pleaded guilty. Previously, there was no statutory rule mandating evidence when pleading guilty to a capital offense. However, due to the confused application and apathetic indifference of courts and lawyers, the Supreme Court incorporated this cautionary requirement in the 1985 Rules on Criminal Procedure to ensure a valid arraignment and advance the proceedings in a criminal action.

ISSUES:

1. Whether or not a plea of guilty based solely on a judicial confession or admission of guilt is sufficient for a conviction.

2. Whether or not a trial court should conduct a searching inquiry when a plea of guilty is made in a capital offense.

3. Whether the trial court failed to ascertain if the accused fully comprehended his guilty plea and its consequences.

4. Whether the trial court failed to consider that the accused made a conditional plea of guilt.

5. Whether the trial court should have restored the former plea of not guilty in light of the plausible insanity defense being set up by the appellant.

6. Whether the trial court violated the constitutional injunction and the 1985 Rules on Criminal Procedure by failing to clearly and distinctly express the facts and law on which its judgment is based.

7. Whether the appellant's admissions in court were made intelligently and voluntarily.

RULING:

1. A clear, definite, and unconditional plea of guilty must be accepted by trial courts. A plea of guilty is regarded as a mitigating circumstance when it is interjected before the prosecution presents its evidence. However, the court cannot relieve the prosecution of its duty to prove the guilt of the accused and the precise degree of his liability through the requisite quantum of evidence.

2. When a capital offense like murder becomes the subject of a positive plea, it is imperative for the trial court to conduct a searching inquiry and receive evidence showing that the accused admits his guilt freely, voluntarily, and with full knowledge of the consequences. The court should also not relieve the accused from adducing evidence to establish the presence of mitigating circumstances in his favor.

3. Yes, the trial court failed to ascertain if the accused fully comprehended his guilty plea and its consequences.

4. Yes, the trial court failed to consider that the accused made a conditional plea of guilt.

5. Yes, the trial court should have restored the former plea of not guilty. The appellant had set up a plausible insanity defense, as evidenced by his admission that he lost his mind at the time of the incident. Moreover, the appellant had been diagnosed with psychosis and schizophrenia, which supports the possibility of a mental affliction. Thus, in light of the insanity defense, the proper course of action was to restore the plea of not guilty.

6. Yes, the trial court violated the constitutional injunction and the 1985 Rules on Criminal Procedure. The court failed to express clearly and distinctly the facts and law on which its judgment is based. It also disregarded the legal citation requirement, as it did not discuss the facts of the case and the qualifying or aggravating circumstances alleged in the information.

7. No, the appellant's admissions in court were not made intelligently and voluntarily. The appellant had been confined in a mental asylum for almost a year and there was no follow-up medical attention given to him. It was evident from the transcripts that he answered questions ambiguously and erratically, indicating the probability of him still suffering from a mental affliction. Therefore, the court should not accept these admissions as valid.

PRINCIPLES:

• A plea of guilty must be clear, definite, and unconditional to be accepted by trial courts.

• A plea of guilty is regarded as a mitigating circumstance when interjected before the prosecution presents its evidence.

• A searching inquiry must be conducted by the trial court when a plea of guilty is made in a capital offense.

• The trial court cannot relieve the prosecution of its duty to prove the guilt of the accused and the precise degree of his liability.

• A guilty plea must be knowing, voluntary, and intelligent. The accused must fully understand the nature of the offense and the consequences of the plea.

• The court must ensure that the accused is informed of the charges against him in a language or dialect that he understands.

• The provisions of the Rules of Court on arraignment, including the assistance of counsel de oficio, must be duly observed.

• On a court's gavel invariably rests at the outset the duty to explain to the accused, who pleads guilty on arraignment to a charge that carries the penalty of capital punishment, the precise nature of the accusation leveled at him and the effect of the attendant circumstances contained and alleged in the information.

• A 'searching inquiry' under the Rules means more than informing the accused that he faces a jail term, but also the exact length of imprisonment under the law and the certainty that he will serve time at the national penitentiary or a penal colony.

• A 'searching inquiry' compels the judge to content himself reasonably that the accused has not been coerced or placed under a state of duress.

• The trial judge must satisfy himself that the accused, in pleading guilty, is truly guilty.

• Judges must be cautioned against the demands of sheer speed in disposing of cases.

• An accused may not foist a conditional plea of guilty on the court in the sense that he admits his guilt provided that a certain penalty will be meted unto him.

• A formal plea of not guilty should properly be entered by the court if an accused admits the truth of some or all the allegations of the information, but interposes excuses or additional facts which, if duly established, would exempt or relieve him in whole or in part of criminal responsibility.

• When a plausible insanity defense is set up, the trial court should restore the former plea of not guilty.

• The trial court must express clearly and distinctly the facts and law on which its judgment is based, in compliance with the constitutional injunction and the 1985 Rules on Criminal Procedure.

• Admissions in court must be made intelligently and voluntarily. In cases involving mental afflictions, proper medical attention and assessment must be given to ensure that the accused is in a sound mental state.