People v. Matilla
REITERATIONFacts
The Antecedents: On the evening of May 19, 1979, Marina Cano Llantada was killed on the highway in Calbayog City. She sustained fatal abdominal wounds, and P30.00 she had shown to her daughter was missing. An information for highway robbery with homicide was filed against Armando Matilla, Ruben Matilla, and Wenifredo Lebajo. Procedural History: Armando Matilla was arrested in Metro Manila and gave an extrajudicial confession to a Calbayog City policeman, allegedly waiving his rights. At his arraignment, Matilla initially pleaded guilty but later claimed maltreatment, leading the trial court to enter a plea of not guilty. Subsequently, Matilla withdrew his plea of not guilty and entered a second plea of guilty to the charge of highway robbery with homicide. The trial court, after requiring the prosecution to present evidence despite the plea, convicted Matilla and sentenced him to death. The case was automatically reviewed by the Supreme Court. The Petition: The accused, through his counsel de oficio, contended that the trial court erred in accepting his second plea of guilty without fully ascertaining his understanding of its meaning and consequences. The Solicitor General agreed that the plea was improvident.
Issue(s)
Whether the trial court erred in accepting the accused's second plea of guilty, and whether the accused's extrajudicial confession was admissible in evidence. Whether the accused committed highway robbery with homicide. Whether the death penalty was properly imposed.
Ruling
The Supreme Court affirmed the trial court's judgment of conviction but commuted the death penalty to reclusion perpetua due to the lack of the requisite ten votes for affirmance. The Court held that the trial court was justified in convicting the accused based on his second plea of guilty.
Ratio Decidendi
On the admissibility of the extrajudicial confession and the validity of the second plea of guilty: The Court acknowledged that the extrajudicial confession was inadmissible under the Constitution because Matilla was not informed of his right to remain silent and to counsel, and the waiver was not shown to be voluntary, knowing, and intelligent. However, the Court found that Matilla's second plea of guilty, entered four months after his initial plea of guilty was withdrawn due to claims of maltreatment, was valid. This second plea, entered after he had withdrawn his plea of not guilty and was fully aware of the consequences, automatically revived his judicial confession of guilt and validated his extrajudicial confession, thereby removing any reasonable doubt as to his guilt. The Court reasoned that the trial court was justified in accepting this second plea, as it was entered with full cognizance of the grave consequences, especially after the fiscal repeatedly refused his request to change the charge to murder. On the commission of highway robbery with homicide: The Court found that the corpus delicti was established. The victim was killed on the highway, and money was missing from her person. While the prosecution's oral evidence presented after the plea of guilty had little probative value, Matilla's second plea of guilty, coupled with his earlier judicial admission of guilt during the first arraignment (despite its subsequent withdrawal due to alleged maltreatment), sufficiently established his commission of the crime. The Court noted that the crime committed was highway robbery with homicide, penalized by death under Presidential Decree No. 532. On the imposition of the death penalty: The Court affirmed the trial court's imposition of the death penalty as mandated by Presidential Decree No. 532 for highway robbery with homicide. However, due to the lack of the required ten votes for affirmance, the death penalty was commuted to reclusion perpetua as per constitutional mandate.
Main Doctrine
A second plea of guilty, entered after a plea of not guilty was substituted for an initial plea of guilty, can validate an otherwise inadmissible extrajudicial confession and cure defects in the custodial interrogation, provided the second plea is entered with full knowledge of its consequences.