People v. Co Hap
REITERATIONFacts
The Antecedents: Co Hap and Tan Lam were charged with violating Executive Order No. 331, Series of 1950, in connection with Republic Act No. 509, for selling evaporated milk at a price higher than the maximum fixed by the executive order. Procedural History: They pleaded guilty and were sentenced by the Court of First Instance of Manila to pay a fine of P5,000 each, with subsidiary imprisonment in case of insolvency, costs, and to be barred from engaging in wholesale and retail business for five years, with a recommendation for deportation. Before the sentence was promulgated, they moved to withdraw their plea of guilty, alleging a misapprehension of the law and that Tan Lam was a mere dummy. The motion was denied, and the sentence was promulgated. The accused appealed, arguing that the trial court abused its discretion in denying their motion to withdraw the plea. The Petition: The accused appealed to the Supreme Court, praying for acquittal on the ground of abuse of discretion by the trial court in denying their motion to withdraw their plea of guilty.
Issue(s)
Whether the trial court abused its discretion in denying the appellants' motion to withdraw their plea of guilty after the same had been entered and the sentence promulgated. Whether the appellants' plea of guilty was made under a misapprehension of the law.
Ruling
The appeal is unmeritorious. The Supreme Court affirmed the sentence imposed by the trial court.
Ratio Decidendi
On the issue of whether the trial court abused its discretion in denying the appellants' motion to withdraw their plea of guilty: The rules of court vest the permission to withdraw a plea of guilty in the sound discretion of the court. In this case, the appellants' plea of guilty was made with the assistance of able counsel. The Court found that the appellants and their counsel likely expected a lighter sentence upon entering the plea of guilty. However, upon learning that the penalty prescribed by law was substantial, they sought to withdraw their plea. The trial court correctly characterized this as an attempt to circumvent the law and an offense against the dignity of the court, refusing to permit such tactics. The Court cited People vs. Manriquez and People vs. Pangilinan to support the principle that a plea of guilty cannot be withdrawn simply because the accused later found the penalty severe or hoped for a milder punishment. The Court emphasized that the accused, with counsel, are deemed to understand the consequences of their acts, and once a plea is entered, it cannot be withdrawn merely due to a change of mind regarding the severity of the penalty. On the issue of whether the appellants' plea of guilty was made under a misapprehension of the law: The allegation that the plea was made under a misapprehension, specifically that Tan Lam was not criminally liable as he was a mere dummy, was found unconvincing. This is because the accused were assisted by able counsel when they entered their plea. The Court inferred that the actual motivation for seeking to withdraw the plea was the realization that the penalty would not be as light as they had hoped, rather than a genuine misunderstanding of their legal liability. The Court reiterated that a plea of guilt is absolute and unconditional, and cannot be affected by extraneous influences or subsequent regrets over the imposed penalty.
Main Doctrine
A plea of guilty, once entered with the assistance of counsel, cannot be withdrawn as a matter of right simply because the accused discovered that the penalty imposed is severe, especially when the withdrawal is sought after the sentence has been promulgated and appears to be motivated by a desire to avoid a penalty that was expected to be lighter.