Facts:

The case involves Alberto Diaz, who was charged with the crime of rape against his 14-year-old daughter, Dorileen Diaz, in an Information dated November 16, 1994. The charge alleged that on September 24, 1994, in the Municipality of Rizal, Palawan, Diaz had carnal knowledge of his daughter against her will, using force and intimidation. During the arraignment on January 13, 1995, Diaz, represented by a Public Attorney, expressed his intention to plead guilty to avoid litigation costs. The trial court conducted a brief inquiry to ascertain whether Diaz understood the legal consequences of his plea.

Diaz admitted to raping his daughter twice and acknowledged that he understood the gravity of the offense and the potential death penalty he faced. The trial court, satisfied with his admission, rendered a decision convicting him of rape and sentenced him to death based solely on his plea and admission. Diaz did not appeal the conviction, but the case was automatically reviewed by the Supreme Court.

Legal Issues:

  1. Did the trial court err in convicting Diaz based solely on his plea of guilty without requiring the prosecution to present evidence of his guilt and the degree of culpability?
  2. Were the procedural safeguards mandated by the Rules on Criminal Procedure followed during the plea and subsequent proceedings?

Arguments:

  • For the Accused (Diaz): Diaz argued that the trial court erred in immediately convicting him without requiring the prosecution to prove his guilt and the precise degree of culpability, as mandated by Section 3, Rule 116 of the Rules on Criminal Procedure. He contended that the court failed to conduct a thorough inquiry into the voluntariness of his plea and did not inform him of his rights and options.

  • For the Prosecution (Solicitor General): The Solicitor General agreed with Diaz's position, acknowledging that the trial court did not follow the required procedures and supported the remand of the case for further proceedings.

Court's Decision and Legal Reasoning:

The Supreme Court found merit in the arguments presented by both Diaz and the Solicitor General. It emphasized that Section 3, Rule 116 mandates a specific procedure when an accused pleads guilty to a capital offense. The court outlined the necessary steps, which include:

  1. Conducting a searching inquiry into the voluntariness and comprehension of the plea.
  2. Requiring the prosecution to present evidence to establish the accused's guilt and the degree of culpability.
  3. Informing the accused of his right to present evidence in his defense.

The Court noted that the trial court's proceedings fell short of these requirements. The inquiry conducted was insufficient, as it primarily focused on the voluntariness of the plea without adequately addressing the need for evidence to support the conviction. The Court highlighted that a conviction in capital offenses cannot rest solely on a plea of guilty, as this could lead to erroneous convictions.

The Supreme Court annulled and set aside the trial court's decision, remanding the case for compliance with the procedural requirements outlined in the Rules on Criminal Procedure.

Significant Legal Principles Established:

  1. A plea of guilty in capital offenses requires a thorough inquiry into its voluntariness and comprehension, along with the presentation of evidence by the prosecution to establish guilt and culpability.
  2. The trial court must inform the accused of his rights and options, including the right to a trial and the right to present evidence.
  3. The procedural safeguards in capital cases are crucial to prevent wrongful convictions and ensure that the state does not err in imposing the death penalty.