"Applying the foregoing principles in this case, it is evident that the trial court failed miserably to comply with the duties imposed by the 2000 Revised Rules. As regards the first duty.... The Court scanned the records of the case to see compliance with the said duty. The search, however, was in vain. The records are barren of any proceeding where the trial court gauged the mindset of the accused when he pleaded guilty.
There is no transcript of stenographic notes which would reveal what actually took place, what words were spoken, what warnings were given, if a translation was made and the manner by which it was made, and whether or not the guidelines for a searching inquiry were duly observed.
The RTC merely stated in its August 20, 2009 Order77 that "[a]ll the contents of the Information as well as the particular crime charged was personally read to accused-appellant in a Cebuano-Visayan dialect."78 The RTC further stated that the court and his counsel explained to accused-appellant the consequences of his plea of guilt and that he will be sentenced and imprisoned. Despite this, accused-appellant maintained his plea of guilty.
Simply, there is no proof whatsoever that the herein judge conducted the searching inquiry required. No other conclusion can be made other than that the RTC failed to discharge its duties. Accused-appellant's plea of guilt is improvident.
What compounded the RTC's strenuous oversight is the fact that the trial court penalized accused-appellant of the crime charged despite failure of the prosecution to present evidence of his guilt. This is in direct contravention of the mandate of the second duty stated in Sec. 3, Rule 116 of the 2000 Revised Rules.
In this regard, the Court agrees with the CA that accused-appellant's guilt for the crime of murder was not proven beyond reasonable doubt. It is beyond cavil that the prosecution did not present any witness, despite being given four (4) separate hearing dates to do so. Thus, the RTC's conviction of accused-appellant relied solely on his improvident plea of guilty.
Lastly, as regard the third requisite, the October 5, 2011 Order of the RTC stated that "[a]ccused[-appellant,] despite the non-reception of prosecution's evidence,] opted not to present any evidence in [sic] his behalf."79 It would appear that accused-appellant waived his right to present evidence under Sec. 3, Rule 116 of the 2000 Revised Rules. However, the same Order and the records of the case are bereft of any showing that the trial court complied with the guidelines promulgated by the Court in People v. Bodoso. Such cavalier attitude of the trial court to the Rules of Court and existing jurisprudence leaves much to be desired.
The RTC's noncompliance with the Rules of Court is beyond dispute. Both the OSG and accused-appellant agree on this point. The divergence, however, is centered on the effect of such noncompliance. Accused-appellant contends that he should be acquitted while the OSG agrees with the CA's order to remand the case for reception of evidence to prove accused-appellant's guilt."
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. BRENDO P. PAGAL, A.K.A. "DINDO," ACCUSSED-APPELLANT. G.R. No. 241257, September 29, 2020, EN BANC.
https://lawphil.net/judjuris/juri2020/sep2020/gr_241257_2020.html
