CRIM PRO DIGEST: People v. Baharan, et.al. (GR No. 188314)

Criminal Procedure, Digest focusing on Rule 116:  Plea of Guilty to Capital Offense; Reception of Evidence


G. R. No. 188314             January 10, 2011


PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee,


vs. 


KHADDAFY JANJALANI, GAMAL B. BAHARAN a.k.a Tapay, ANGELO Trinidad a.k.a Abu Khalil, GAPPAL BANNAH ASALI a.k.a Abu Solaiman, ROHMAT ABDURROHIM a.k.a Jackie or Zaky, and other JOHN and Jane DOES, Accused,

GAMAL B. BAHARAN a.k.a Tapay, ANGELO TRINIDAD a.k.a Abu Khalil and ROHMAT ABDURROHIM a.k.a Abu Jackie or Zaky, Accused-Appellants.


SERENO, J.:


DOCTRINE:

The court emphasizes the importance of a searching inquiry into the voluntariness and full comprehension of the consequences of quilty plea, especially in cases involving capital offense.


FACTS:

  • On February 14, 2005, an RRCG bus traveling southbound via EDSA had Bahaan and Trinidad on board, who later exited at Ayala Avenue;

  • Shortly after their departure, an explosion occured, leading to the bus being engulfed in flames;

  • Abu Sayyaf Group's spokesperson, Abu Solaiman, announced a "gift" for President Gloria Macapagal-Arroyo before the incident;

  • Trinidad confessed his involvement in an exclusive interview with ABS-CBN News Network;

  • The bus conductor positively identified Baharan and Trinidad as the Individuals on the bus;

  • Accused-appellants, Baharan and Trinidad, argued that the trial court did not conduct a searching inquiry after they had changed their plea from "not guilty" to "guilty".

  • They later asserted that the guilt was not proven beyond reasonable doubt and pointed out that the testimony of the conductor was merely circumstantial, while that of Asali as to the conspiracy was insufficient.

ISSUE:

  1. Whether or not the trial court gravely erred in accepting plea of guilt despite insufficiency of searching inquiry into the voluntariness and full comprehension of the consequences of the said plea.

  2. Whether or not the trial court gravely erred in finding that the guilt of Accused-Appellants for the crimes charged had been proven beyond reasonable doubt.


RULING:

  1. NO. The court emphasizes the duty of judges to conduct a searching inquiry to ensure the accused's plea is voluntary and informed. In this case, considering prior guilty please, confessions and stipulations, the court finds no need to question the sufficiency of the "searching inquiry."

  2. NO. The guilt of appellants, Baharan and Trinidad, is sufficiently established through corroborating testimonies, judicial admissions, and extrajudicial confessions. The court highlights the admissibility of extrajudicial confessions as judicial admissions, emphasizing that co-accused can be implicate based on such testimony. The evidence proves guilt beyond reasonable doubt.


Legal Basis & Principles:

  1. Searching Inquiry Requirement: As established in People v. Aphudan, trial judges must refrain from hastily accepting an accused's guilty of plea. The court emphasizes a judge's duty to ensure the accused fully comprehend the pleas meaning and the consequence of an inevitable conviction.

  2. Procedure under Rule 116, Section 3: When an accused pleads guilty to a capital offense. It mandates a searching inquiry into voluntariness and comprehension, requiring the prosecution to prove guilt and the degree of culpability.

  3. Duty of Judges: Judges are mandated by rules to conduct a searching inquiry, ensuring the accused wasn't under a coercion, duress, or misunderstanding the plea's significance. This duty is stringent and mandatory.

  4. Contextual Consideration: Acknowledging the context of the case, especially in re-arraignment situations, the court may ind the searching inuiry unnecessary if prior guilty please and confessions exist. The pleas sufficiency may not be questioned if it's not the sole basis for the condemnatory judgment.

  5. Conviction and Independent Evidence: Even if the searching inquiry is not fully complied with, convictions can stand if based on independent evidence proving the accused's commission of the offense, as declared in People v. Oden and reiterated in People v. Nadera.

  6. Corroborating Testimonies and Admissions: The guilt of Accused-appellants can be established through corroborating testimonies, judicial admissions, and extra judicial confessions. Statements made by co-conspiraors during trial, if repeated, become judicial admissions, making them admissible against co-accused.

  7. Upholding Trial Court Findings: The court upholds the trial court's findings of guilt when supported by sufficient and credible evidence, even if a guilt please was involved. The conviction is sustained if based on independent evidence.


SOURCE:

G.R. No. 188314. (n.d.). https://lawphil.net/judjuris/juri2011/jan2011/gr_188314_2011.html


                                

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