People v. Mendoza
REITERATIONFacts
The Antecedents: Andy de los Santos, Jr. was charged with estafa in three separate informations for issuing postdated checks as payment for lumber, which checks were subsequently dishonored for lack of funds. The accused was furnished with the complainant's affidavit and did not present a counter-affidavit. Procedural History: At his arraignment, De los Santos pleaded not guilty. However, at a subsequent hearing, he withdrew his plea of not guilty and substituted it with a plea of guilty. After interrogation by the respondent judge, where De los Santos affirmed his understanding of the consequences and voluntariness of his plea, the court accepted the plea. The defense moved for the appreciation of mitigating circumstances of plea of guilty and voluntary surrender, to which the fiscal did not object. The trial court rendered three separate judgments of conviction, imposing indeterminate penalties and ordering payment of indemnities, giving De los Santos the benefit of the two extenuating circumstances. The Petition: Three days after the promulgation of the judgments, De los Santos' counsel filed a motion to set aside the judgments of conviction, seeking to withdraw the plea of guilty and substitute it with a plea of not guilty, pursuant to Section 6, Rule 118 of the Rules of Court. The motion was not set for hearing and was submitted for resolution. The trial court, noting that the judgments had not yet become final, set them aside, entered a plea of not guilty for the accused, and scheduled the cases for trial. The fiscal moved for reconsideration, which was reiterated in a second motion, stressing that the initial motion to set aside was not based on any ground and was not set for hearing. The trial court denied the second motion for reconsideration. When the fiscal could not present witnesses due to their unavailability, the court dismissed the cases and ordered the release of De los Santos.
Issue(s)
Whether the trial court gravely abused its discretion in setting aside the judgments of conviction based on a plea of guilty. Whether the trial court gravely abused its discretion in allowing the accused to withdraw his plea of guilty and substitute it with a plea of not guilty. Whether the trial court gravely abused its discretion in dismissing the cases due to the prosecution's failure to present evidence after setting aside the judgments of conviction.
Ruling
The Supreme Court reversed and set aside the orders of the trial court dated September 14 and 21, and October 5, 1981. The judgments of conviction against the accused were reinstated and declared final and executory.
Ratio Decidendi
On the issue of setting aside judgments of conviction based on a plea of guilty: The Court held that Section 6, Rule 118 of the Rules of Court empowers the trial court to set aside a judgment of conviction based on a plea of guilty, but this power must be justified by some compelling reason such as error, fraud, illegality, or manifest injustice. The trial court is not invested with unbridled discretion to do so merely because the judgment has not yet become final. The exercise of this power should not be a ministerial or routinary duty on a mere request or petition of the accused. The motion to withdraw a plea of guilty should have a rational basis, stating meritorious defenses, and should be set for hearing with the prosecution being heard. The trial court should state its reasons for setting aside the judgment and allowing the change of plea, and should not act in a perfunctory manner, as the accused should not trifle with the court by gambling on the result of their change of pleas. The Court cited California and Kentucky jurisprudence emphasizing the need for a strong and convincing showing of fraud, duress, or other force overreaching the free will of the accused, or evidence of fear, deceit, or coercion. On the issue of allowing withdrawal of plea and substitution with not guilty: The Court found that the trial court committed a grave abuse of discretion, amounting to lack of jurisdiction, in setting aside the judgments of conviction on the basis of De los Santos' "flimsy and whimsical" petition, which contained no reason for the change of plea. The trial court acted with deplorable precipitancy in allowing the withdrawal of the plea and entering a plea of not guilty without requiring the accused to explain why he had changed his mind. The Court reiterated the settled rule that where the record conclusively shows that the accused freely, voluntarily, and spontaneously entered a plea of guilty with a full realization of its meaning and consequences, after it was clearly explained by the court, the accused shall not be allowed to withdraw that plea. The trial court's action in this regard disregarded the importance and respect due to its own judgments and was influenced by the accused's capricious conduct. On the issue of dismissing the cases after setting aside the judgments: The dismissal of the cases was a consequence of the trial court's erroneous orders setting aside the judgments of conviction and allowing the change of plea. Since the Supreme Court reinstated the judgments of conviction, the subsequent dismissal based on the prosecution's failure to present evidence becomes moot. The Court emphasized that the accused should not be allowed to trifle with solemn judicial proceedings by changing his plea solely because the penalty meted out was not satisfactory to him, as seen in People vs. Pangilinan. The trial court's actions in setting aside the judgments, allowing the change of plea, and subsequently dismissing the cases were all tainted with grave abuse of discretion.
Main Doctrine
A trial court commits grave abuse of discretion in setting aside a judgment of conviction based on a plea of guilty, and allowing the withdrawal of such plea and substitution with a plea of not guilty, without a compelling reason such as fraud, duress, or manifest injustice, and without affording the prosecution an opportunity to be heard on the motion.