Accused pleads guilty to a capital offense | Court's duty |

 



SC: The plea of guilt made by the accused
does not relieve the prosecution of the
duty to prove the guilt of the accused
beyond reasonable doubt

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  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 [shall] require the prosecution to prove his guilt and the precise degree of culpability. The accused may present evidence in his behalf[.]


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Again, in the 1917 case of U.S. v. Jamad (Jamad),  this Court noted that "[notwithstanding the plea of 'guilty,' several witnesses were examined, under the well-settled practice in this jurisdiction which contemplates the taking of additional evidence in cases wherein pleas of 'guilty' are entered to complaints or information charging grave crimes, and more especially crimes for which the prescribed penalty is death." Hence, the following guidelines were adopted:


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We may say then, in response to the request for a ruling on this subject by the Attorney-General: 


(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.

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 (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.

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(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.


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(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.

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(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.


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(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.


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The essence of the requirement of the
conduct of a searching inquiry is the
ascertainment of the accused's
voluntariness and full comprehension
of the consequences of his plea |
  


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The searching inquiry requirement means more than informing cursorily 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. The searching inquiry of the trial court must be focused on: (1) the voluntariness of the plea, and (2) the full comprehension of the consequences of the plea.
  

Not infrequently indeed, an accused pleads guilty in the hope of lenient treatment, or upon bad advice, or because of promises of the authorities or parties of a lighter penalty should he admit guilt or express remorse. It is the duty of the judge to see to it that the accused does not labor under these mistaken impressions.''

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A searching inquiry likewise compels the judge to content himself reasonably that the accused has not been coerced or placed under a state of duress — and that his guilty plea has not therefore been given improvidently — either by actual threats of physical harm from malevolent quarters or simply because of his, the judge's, intimidating robes.


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  Further, a searching inquiry must not only comply with the requirements of Sec. 1, par. (a), of Rule 116 but must also expound on the events that actually took place during the arraignment, the words spoken and the warnings given, with special attention to the age of the accused, his educational attainment and socio-economic status as well as the manner of his arrest and detention, the provision of counsel in his behalf during the custodial and preliminary investigations, and the opportunity of his defense counsel to confer with him. 

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These matters are relevant since they serve as trustworthy indices of his capacity to give a free and informed plea of guilt. 


 Lastly, the trial court must explain the essential elements of the crime he was charged with and its respective penalties and civil liabilities, and also direct a series of questions to defense counsel to determine whether he has conferred with the accused and has completely explained to him the meaning of a plea of guilty. This formula is mandatory and absent any showing that it was followed, a searching inquiry cannot be said to have been undertaken.

   

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Simply, the requirement ensures that the plea of guilty was voluntarily made and that the accused comprehends the severe consequences of his plea. This means asking a myriad of questions which would solicit any indication of coercion, misunderstanding, error, or fraud that may have influenced the decision of the accused to plead guilty to a capital offense.


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Thus, in every case where the accused enters a plea of guilty to a capital offense, especially when he is ignorant with little or no education, the proper and prudent course to follow is to take such evidence as are available and necessary in support of the material allegations of the information, including the aggravating circumstances therein enumerated, not only to satisfy the trial judge himself but also to aid the Supreme Court in determining whether the accused really and truly understood and comprehended the meaning, full significance, and consequences of his plea.

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The plea of guilt made by the accused

does not relieve the prosecution of the

duty to prove the guilt of the accused

beyond reasonable doubt | 









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. 


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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.

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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.

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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.

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Read the full decision at


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