People v. Rapirap
REITERATIONFacts
The Antecedents: Alicia Rapirap was charged with, tried, and convicted by the Municipal Court of Naga City for less serious physical injuries, and sentenced to pay a fine of P25.00. Procedural History: The accused appealed to the Court of First Instance (CFI) of Camarines Sur. Upon arraignment in the CFI, she withdrew her plea of not guilty and voluntarily pleaded guilty to the crime as described in the information, which detailed the unlawful assault upon Remedios Braca with a piece of wood, causing contusions requiring medical attendance for three to seven days and incapacitating the complainant from performing her customary labor for the same period. The information also stated that Remedios Braca suffered damages in the amount of P200.00. The Petition: After pleading guilty, the accused's counsel requested the court to impose a penalty of P20.00, considering the plea of guilt. This was denied. Subsequently, the accused sought to withdraw her appeal, which was also denied. The CFI then sentenced the accused to suffer eleven (11) days of arresto menor, to pay P200.00 in damages to the offended party (or suffer subsidiary imprisonment in case of insolvency), and to pay the costs.
Issue(s)
Whether the Court of First Instance (CFI) abused its discretion in refusing to allow the withdrawal of the appeal after the Appellant had already entered a plea of guilty.
Ruling
The Supreme Court affirmed the judgment of the Court of First Instance, holding that the refusal to allow the withdrawal of the appeal was proper. The Court ruled that a plea of guilty, entered after the appeal to the Court of First Instance, effectively constitutes a trial on the merits, thereby precluding the withdrawal of the appeal under Section 21, Rule 118 of the Rules of Court. The Court also found no abuse of discretion in the lower court's denial of the withdrawal, as it was made only when the court appeared disposed to impose a higher penalty.
Ratio Decidendi
On Issue 1: The Supreme Court held that the withdrawal of an appeal under Rule 118 of the Rules of Court is a matter of sound judicial discretion and not an absolute right of the accused. The rule specifically provides that such withdrawal should be allowed only before the trial of the case on appeal. Applying the doctrine in People v. Ilagan, the Court clarified that while a trial usually begins after a plea of not guilty, a plea of guilty serves as a functional substitute for the trial itself because it admits all material facts alleged in the information. Consequently, when the Appellant pleaded guilty, the case was for all intents and purposes tried on its merits and submitted for decision, leaving the CFI with no alternative but to impose the penalty prescribed by law. The Court further noted that the motion to withdraw was clearly a tactical move made only after the Appellant realized the CFI intended to impose a harsher penalty than the Municipal Court. To permit withdrawal under such circumstances would allow parties to 'trifle with the solemn judicial procedure' and treat courts like a marketplace, which the law does not permit. Finally, the Court affirmed that the plea of guilty could not be considered a mitigating circumstance because it was entered only upon appeal in the CFI, consistent with People v. Herminio.
Main Doctrine
The withdrawal of an appeal under Section 21, Rule 118 of the Rules of Court must be made before the trial of the case on appeal. A plea of guilty, taken after the case has been appealed to the Court of First Instance, effectively takes the place of a trial and removes the necessity of presenting further evidence, thus precluding the withdrawal of the appeal.