People v. Asoy
REITERATIONFacts
The Antecedents: The accused, Wenefredo D. Asoy, was charged with Rape with Homicide for allegedly raping and killing his sister, Ester Dimson Asoy. The Information alleged that on December 22, 1996, the accused, armed with a bolo, with lewd designs and by means of force and intimidation, had carnal knowledge with Ester against her will. It further alleged that by reason and on the occasion of the rape, the accused, with deliberate intent and intent to kill, hacked Ester on different parts of her body, causing her death. The victim sustained incised wounds on the neck, contusions on the arm, and a fractured rib. The autopsy report also indicated the presence of non-motile spermatozoa in the vaginal canal and cervix, and concluded that the cause of death was shock and hemorrhage, massive, due to the incised wound of the neck, and that physical virginity was lost. Procedural History: Upon arraignment on March 4, 1997, the accused, assisted by his counsel, pleaded guilty to the crime charged. The Regional Trial Court (RTC) of Cariaga, Leyte, Branch 13, reset the sentencing and ordered the prosecution witnesses to testify to determine the accused's culpability. The prosecution presented testimonies from the victim's mother, a nephew who found the body, an SPO4 who conducted the investigation and confiscated a bolo, and the medico-legal officer who conducted the autopsy. The accused's counsel manifested that they had no evidence to contradict the prosecution's evidence and submitted the case for decision. The RTC found the accused guilty of Rape with Homicide and sentenced him to suffer the penalty of death. The Petition: The accused appealed the RTC decision, arguing that the RTC gravely erred in proceeding with the trial despite the accused's improvident plea of guilty and in convicting him despite the alleged insufficiency of evidence.
Issue(s)
Whether the plea of guilty entered by the accused was improvident. Whether there was sufficient evidence to convict the accused of Rape with Homicide.
Ruling
The Supreme Court set aside the assailed decision, ordered the trial court to re-arraign the accused, and to conduct proper proceedings thereafter. The Court found the plea of guilty to be improvident due to procedural lapses by the trial court.
Ratio Decidendi
On the issue of the improvident plea of guilty: The Supreme Court held that the trial court gravely erred in proceeding with the trial despite the accused's improvident plea of guilty. The Court emphasized the mandatory and stringent procedural requirements concerning the arraignment and plea of an accused, particularly when the offense charged is a capital offense. Section 1(a) of Rule 116 of the Revised Rules of Criminal Procedure mandates that the accused must be furnished a copy of the Information, and the same must be read in the language or dialect known to him. Section 3 of the same Rule requires the court to conduct a searching inquiry into the voluntariness and full comprehension of the consequences of the plea when the accused pleads guilty to a capital offense. In this case, the Certificate of Arraignment merely stated that the accused was informed of the nature of the charge by reading the Information in English, a language the accused, being a "probinsiyano," was obviously unfamiliar with. Furthermore, the trial court failed to conduct a searching inquiry into the voluntariness and comprehension of the plea. The Court noted that the accused's mother testified that the accused confessed only to killing his sister, not raping her, which raised serious doubt about whether the accused understood the charge of rape with homicide. Therefore, the arraignment was nullified due to the trial court's failure to comply with the mandatory rules, rendering the plea of guilty improvident. On the issue of the sufficiency of evidence to convict the accused of Rape with Homicide: Consequently, the Court did not need to discuss the second assigned error regarding the sufficiency of evidence.
Main Doctrine
A plea of guilty to a capital offense is considered improvident if the trial court fails to conduct a searching inquiry into the voluntariness and full comprehension of the consequences of the plea, and fails to read the Information in a language or dialect known to the accused.