People v. Verano, Jr.
REITERATIONFacts
The Antecedents: Pedro Verano, Jr. y Marasarti, alias Juan and Silvestre Verano, was charged with Robbery with Homicide for allegedly robbing Manuela J. Ponce Vda. de Trinidad and Remedios Trinidad y Ponce of various items totaling P1,498.00 and, during the commission of the crime, killing Remedios Trinidad y Ponce with evident premeditation and treachery. Procedural History: The accused pleaded not guilty. While the prosecution was presenting evidence, he withdrew his plea and pleaded guilty, invoking the benefits of Presidential Decree (P.D.) No. 603. He testified on the voluntariness of his plea and the absence of restraint. The trial court found him guilty beyond reasonable doubt of robbery with homicide and sentenced him to life imprisonment, to indemnify the heirs of Remedios Trinidad y Ponce for death and property taken, and to pay costs. He was entitled to the benefits of Article 29 of the Revised Penal Code. The Petition: The accused appealed, assigning two errors: (I) the trial court gravely erred in convicting him based solely on his plea of guilty, and (II) the trial court gravely erred in not giving him the benefit of P.D. 603, Article 192.
Issue(s)
Whether the trial court gravely erred in convicting the defendant-appellant Pedro Verano, Jr. of the crime of robbery with homicide on the strength of his plea of guilty. Whether the trial court gravely erred in not giving him the benefit of P.D. 603, Article 192.
Ruling
The appealed judgment is MODIFIED in that appellant, Pedro Verano, shall suffer an indeterminate penalty of ten (10) years and one (1) day of prision mayor, as minimum, to seventeen (17) years, four (4) months, one (1) day of reclusion temporal, as maximum, and shall indemnify the heirs of the victim, Remedios Trinidad y Ponce, in the amount of THIRTY THOUSAND (P30,000.00) PESOS. The rest of the judgment is AFFIRMED.
Ratio Decidendi
On the conviction based on a plea of guilty: The Supreme Court affirmed the trial court's conviction, holding that the trial court did not improvidently accept the plea of guilty. The records show that the trial court conducted a searching inquiry into the accused's plea, asking him if he understood the charge, had conferred with his lawyer, was informed of the consequences, and if the plea was voluntary and free from restraint. The accused answered affirmatively to most questions, except that he was not influenced by outside factors. The Court reiterated its consistent ruling that even in capital offenses, a plea of guilty is valid if the court ensures the accused fully understands the nature of the charges and the consequences of the plea, often by requiring the presentation of evidence. The defense counsel's failure to seasonably challenge the proceedings also precluded raising the issue for the first time on appeal. On the benefit of P.D. 603 (Youthful Offender): The Supreme Court denied the application of P.D. 603, Article 192, for the suspension of sentence. The Court clarified that the benefits of the Child and Youth Welfare Code apply to youthful offenders, defined as those between nine and twenty-one years of age at the time of the offense. However, the accused was over 21 years of age at the time of his conviction, thus no longer a youthful offender. While he was entitled to the privileged mitigating circumstance of minority because he was a minor at the time of the offense, his plea of guilty, entered after the trial had begun, did not mitigate his culpability. The Court also noted that the abolition of capital punishment in the 1987 Constitution changed the imposable penalty for robbery with homicide to reclusion temporal in its maximum period to reclusion perpetua. Applying the Indeterminate Sentence Law, the penalty was adjusted.
Main Doctrine
A plea of guilty, even in capital offenses, is valid if the trial court conducts a searching inquiry into the voluntariness and comprehension of the plea, requires the prosecution to present evidence, and allows the accused to present evidence. The benefits of the Child and Youth Welfare Code (PD 603) apply only if the offender is a minor at the time of conviction.