PEOPLE OF THE PHILIPPINES

---vs--Rolando Camay
Plea to a capital offense

July 29, 1987

GR L-51306

FACTS:
1. This petition is an automatic review from a decision of the trial court finding the accused
guilty of the crime of Robbery with Homicide and sentenced to a capital punishment of
death.
2. (FOR READING PLEASURE) The accused is a neighbor of the victim, a pregnant mother
who was sleeping with her daughter at the time of the crime. He broke into the house and
demanded money from the helpless mother, and after refusing to do so, he repeatedly
slashed her until dead.
3. Respondent accused pleaded guilty to the offense.
4. Hence this petition.
ISSUE: W/N The accuseds plea of guilty is valid (YES)
Held:
According to R116 S3, the court shall conduct a searching inquiry into the voluntariness and full
comprehension of the consequences when the accused pleads guilty. Under the new rules, the
trial court must do 3 things after a plea of guilty to a capital punishment:
1. Conduct a searching inquiry into the voluntariness and full comprehension of the
consequences of his plea
2. Court must require the prosecution to present evidence to prove the guilt of the accused
3. Court must also ask the accused if he likes to present evidence in his behalf
On top of this, SC held that even if the trial court is satisfied that the plea of guilty is entered with full
knowledge of its meaning and consequences, SC must still require the introduction of evidence to establish
the guilt of the accused. In a sense, the searching inquiry must still be followed by the SC even if the
Trial Court is satisfied with the voluntariness of the plea in order to establish the guilt of an
accused.
While there is no law requiring the court to call witnesses for the purpose of establishing guilt
whenever there is a guilty plea, it is discretionary upon the courts. Although several
jurisprudence advices the trial court to receive evidence and ensure that the accused understands
his guilty plea, the same jurisprudence recognizes the discretion of the trial court to convict the
accused merely on his guilty plea, if it is convinced that the taking of evidence is unnecessary.
In this case, the trial court judge and the accuseds counsel de officio complied with all
requirements faithfully. However, the SC reduced the penalty to reclusion perpetua, but did not
state the reason why.