People v.
Janjalani
G.R. No. 188314 (January 10, 2011)
Topic: Rule 116: Arraignment and Plea
Issue: Whether or not the trial court gravely erred in accepting accused-appellants’ plea of guilt despite
insufficiency of searching inquiry into the voluntariness and full comprehension of the consequences of the
said plea
Held: No
Ratio: As early as in People v. Apduhan, the Supreme Court has ruled that "all trial judges … must refrain
from accepting with alacrity an accused's plea of guilty, for while justice demands a speedy administration,
judges are duty bound to be extra solicitous in seeing to it that when an accused pleads guilty, he
understands fully the meaning of his plea and the import of an inevitable conviction." Thus, trial court
judges are required to observe the following procedure under Section 3, Rule 116 of the Rules of Court:
SEC. 3. Plea of guilty to capital offense; reception of evidence. — When the accused pleads guilty to a
capital offense, the court shall conduct a searching inquiry into the voluntariness and full comprehension
of the consequences of his plea and shall require the prosecution to prove his guilt and the precise degree
of culpability. The accused may also present evidence in his behalf. (Emphasis supplied)
The requirement to conduct a searching inquiry applies more so in cases of re-arraignment. In People v.
Galvez, the Court noted that since accused-appellant's original plea was "not guilty," the trial court should
have exerted careful effort in inquiring into why he changed his plea to "guilty." According to the Court:
The stringent procedure governing the reception of a plea of guilt, especially in a case involving the death
penalty, is imposed upon the trial judge in order to leave no room for doubt on the possibility that the
accused might have misunderstood the nature of the charge and the consequences of the plea.
Likewise, the requirement to conduct a searching inquiry should not be deemed satisfied in cases in which
it was the defense counsel who explained the consequences of a "guilty" plea to the accused, as it
appears in this case. In People v. Alborida, this Court found that there was still an improvident plea of
guilty, even if the accused had already signified in open court that his counsel had explained the
consequences of the guilty plea; that he understood the explanation of his counsel; that the accused
understood that the penalty of death would still be meted out to him; and that he had not been intimidated,
bribed, or threatened.
We have reiterated in a long line of cases that the conduct of a searching inquiry remains the duty of
judges, as they are mandated by the rules to satisfy themselves that the accused had not been under
coercion or duress; mistaken impressions; or a misunderstanding of the significance, effects, and
consequences of their guilty plea. This requirement is stringent and mandatory.
Nevertheless, we are not unmindful of the context under which the re-arraignment was conducted or of the
factual milieu surrounding the finding of guilt against the accused. The Court observes that accused
Baharan and Trinidad previously pled guilty to another charge – multiple murder – based on the same act
relied upon in the multiple frustrated murder charge. The Court further notes that prior to the change of
plea to one of guilt, accused Baharan and Trinidad made two other confessions of guilt – one through an
extrajudicial confession (exclusive television interviews, as stipulated by both accused during pretrial), and
the other via judicial admission (pretrial stipulation). Considering the foregoing circumstances, we deem it
unnecessary to rule on the sufficiency of the "searching inquiry" in this instance. Remanding the case for
re-arraignment is not warranted, as the accused’s plea of guilt was not the sole basis of the condemnatory
judgment under consideration.
