THE PEOPLE OF THE PHILIPPINES, PLAINTIFF, VS. ROLANDO CAMAY, ACCUSED.

People versus Camay

The Case

This is the People of the Philippines against Rolando Camay, an automatic review of a judgment of conviction in a capital case. The accused, with the assistance of counsel, pleaded guilty to robbery with homicide, and the trial court sentenced him to death. The case matters because it fixes, in exact procedural terms, what a trial judge must do before accepting a plea of guilty to a capital offense: the judge must conduct a searching inquiry into the voluntariness and full comprehension of the plea, must require the prosecution to prove guilt and the precise degree of culpability, and must offer the accused the chance to present evidence. It is a case about procedure as a safeguard of life.

Procedural History

The accused was charged before the Court of First Instance of the Sixteenth Judicial District sitting at Baganga, Davao Oriental, with robbery with homicide. Assisted by counsel de oficio, he entered a plea of guilty. The trial court conducted its inquiry, required the prosecution to present evidence, and then rendered a decision finding him guilty, imposing the extreme penalty of death, ordering indemnity to the heirs of the deceased, and requiring payment of the stolen amount and the costs. Because the penalty imposed was death, the case came to the Supreme Court on automatic review. Counsel de oficio filed a memorandum in lieu of the appellant's brief, and the Solicitor General filed a manifestation and motion in lieu of the appellee's brief; both recommended affirmance of the decision under review.

Facts

At around nine o'clock in the evening of May 6, 1978, Angelita Madianda, then six years old, and her mother, who was six months pregnant, were lying side by side inside their house at Baugo, Caraga, Davao Oriental, ready to sleep. The accused barged into the house and demanded money from the mother. When she said they had no money to give, he hacked her several times, and she was unable to fight back. The accused lived in the same barrio and was a frequent visitor in their house, which is why the child easily recognized him.

The victim's husband, Pilosopo Madianda, testified that on that evening he was in Barrio Albar making copra, and when he arrived at their house the following day he found his wife dead. He also observed that their trunk had been forcibly opened and that the money inside, amounting to 600 pesos, was missing. The prosecution presented the death certificate of Enriquita Madianda and, as its last witness, Judge Manuel Castro of the Municipal Circuit Court of Baganga and Caraga, who identified the accused's confession dated May 11, 1978 and testified that the accused personally subscribed and swore to it before him after the judge explained its contents.

After the prosecution made its formal offer of evidence, the accused was asked to present his evidence, but maintaining his plea of guilty, he submitted the case for decision through his counsel de oficio. The trial court rendered its verdict of guilty, and the case went up for automatic review.

Issues

• Whether or not the trial court complied with the procedure required when an accused pleads guilty to a capital offense.
• Whether or not the guilt of the accused was proven beyond reasonable doubt despite his plea of guilty.
• Whether or not the penalty of death and the award of indemnity should be sustained.

Applicable Provisions

Section 3 of Rule 116 of the Rules on Criminal Procedure, which took effect on January 1, 1985, provides:

When an 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 require the prosecution to prove his guilt and the precise degree of culpability. The accused may also present evidence in his behalf.

This is the strict procedure the Court measures the trial court's conduct against, and it lays down the three duties of the judge after a plea of guilty to a capital offense.

The old rule, Section 5 of Rule 118 of the Rules of Court, provides:

Where the defendant pleads guilty to a complaint or information, if the court accepts the plea and has discretion as to the punishment for the offense, it may hear witnesses to determine what punishment shall be imposed.

The Court notes that the old rule is more succinct, and the new formulation is a capsulization of it and of the pertinent jurisprudence.

Ruling

On the first issue, the Court held that the trial judge complied faithfully with the strict procedure and more. After extensive interviews between the accused and his counsel de oficio, the judge asked him a series of questions fully informing him of the nature of the charge and its grave consequences. Even after the plea had been entered and the certificate of arraignment signed, the court asked three questions: whether he knew that his plea of guilty was for the crime of robbery with homicide; whether he understood the gravity of the penalty of death by electric chair; and whether, knowing the severity of the penalty, he still insisted on his plea. He answered all three in the affirmative. The court then ordered the prosecution to present its witnesses in the presence of the accused and his counsel, and afterward asked the accused whether he wished to present evidence.

On the second issue, the Court was convinced that guilt had been proven beyond reasonable doubt in the light of the overwhelming evidence of the prosecution, fully corroborated and substantiated by the plea of guilty. The Court stressed that even where the trial court is satisfied that the plea was entered with full knowledge of its meaning and consequences, it must still require the introduction of evidence to establish guilt and the degree of culpability, as the proper norm to aid the Court in determining whether the accused truly comprehended the meaning, full significance, and consequences of his plea.

On the third issue, the Court affirmed the judgment but modified it, reducing the penalty to reclusion perpetua and increasing the indemnity to the heirs of the deceased to 30,000 pesos.

Doctrine

When an accused pleads guilty to a capital offense, the trial court must do three things: conduct a searching inquiry into the voluntariness and full comprehension of the consequences of the plea; require the prosecution to prove the guilt of the accused and the precise degree of culpability; and ask the accused whether he desires to present evidence in his behalf and allow him to do so if he so desires. Even if the court is satisfied that the plea was knowing and voluntary, it must still require evidence of guilt and of the degree of culpability. This duty is not discretionary under the amended rule; it is enjoined, and it exists to protect the accused and to aid the reviewing Court.

Disposition

The judgment of conviction was affirmed, with the modification that the penalty was reduced to reclusion perpetua and the indemnity to the heirs of the deceased was increased to 30,000 pesos, with costs against the accused.

Remember This

Memorize the three-fold duty after a plea of guilty to a capital offense: searching inquiry, proof of guilt and precise degree of culpability, and the offer to present evidence. Examiners use this case to test the procedure for accepting a plea of guilty in capital offenses and the requirement that the prosecution still prove guilt despite the plea.