People vs Janjalani
Accused-appellants Baharan and Trinidad argue that the trial court did not conduct a searching inquiry after they had changed their plea from "not guilty" to "guilty."
In their second assignment of error, accused-appellants assert that guilt was not proven beyond reasonable doubt. They pointed out that the testimony of the conductor was merely circumstantial, while that of Asali as to the conspiracy was insufficient.
Accused-appellants raise the following assignment of errors:
The trial court gravely erred in accepting accused-appellants' plea of guilt despite insufficiency of searching inquiry into the voluntariness and full comprehension of the consequences of the said plea.
The trial court gravely erred in finding that the guilt of accused-appellants for the crimes charged had been proven beyond reasonable doubt.
Trial court judges are required to observe the following procedure under Section 3, Rule 116 of the Rules of Court:
SEC. 3. Plea of guilty to capital offense; reception of evidence. -- When the 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 shall require the prosecution to prove his guilt and the precise degree of culpability. The accused may also present evidence in his behalf.
The requirement to conduct a searching inquiry applies more so in cases of re-arraignment.
Likewise, the requirement to conduct a searching inquiry should not be deemed satisfied in cases in which it was the defense counsel who explained the consequences of a "guilty" plea to the accused, as it appears in this case.
The conduct of a searching inquiry remains the duty of judges, as they are mandated by the rules to satisfy themselves that the accused had not been under coercion or duress; mistaken impressions; or a misunderstanding of the... significance, effects, and consequences of their guilty plea. This requirement is stringent and mandatory.
The Court upholds the findings of guilt made by the trial court as affirmed by the Court of Appeals.