Case Brief: People vs. Estomaca

G.R. Nos. 117485-86 April 22, 1996
PEOPLE OF THE PHILIPPINES, plaintiff-appellee,
MELCHOR ESTOMACA y GARQUE, accused-appellant.

The accused, an illiterate laborer, was charged guilty of five instances of rape of her daughter. When he was arraigned, he pleaded guilty to all of the complaints against him. Eventually however, he informed the court that he was only guilty of two counts of rape, that the other three might have been done by the victim’s boyfriend and he was merely blamed for it.
Since he was charged for a heinous crime, the case was elevated to Supreme Court, which found the arraignment process of the accused to be questionable.

Whether or not the arraignment was valid.

No. Section 1(a) of Rule 116 requires that the arraignment should be made in open court by the judge himself or by the clerk of court furnishing the accused a copy of the complaint or information with the list of witnesses stated therein, then reading the same in the language or dialect that is known to him, and asking him what his plea is to the charge. The requirement that the reading be made in a language or dialect that the accused understands and known is a mandatory requirement, just as the whole of said Section 1 should be strictly followed by trial courts. This the law affords the accused by way of implementation of the all-important constitutional mandate regarding the right of an accused to be informed of the precise nature of the accusation leveled at him and is, therefore, really an avenue for him to be able to hoist the necessary defense in rebuttal thereof.  It is an integral aspect of the due process clause under the Constitution.
In the case at hand, the arraignment appears to have consisted merely of the bare reading of the five complaints, synthetically and cryptically reported in the transcript. Moreover, the court found out that the complaint or information was not read to the accused in the language known to him, as his local dialect was kinaray-a and the lower court conducted the arraignment in Ilonggo.
The bottom line of the rule is that a plea of guilt must be based on a free and informed judgment. Thus, the searching inquiry of the trial court must be focused on: (1) the voluntariness of the plea; and (2) the full comprehension of the consequences of the plea. The questions of the trial court failed to show the voluntariness of the plea of guilt of the appellant nor did the questions demonstrate appellants full comprehension of the consequences of the plea. The records do not reveal any information about the personality profile of the appellant which can serve as a trustworthy index of his capacity to give a free and informed plea of guilt. The age, socio-economic status, and educational background of the appellant were not plumbed by the trial court.
The Supreme Court remanded the two criminal cases where the accused pleaded guilty back to the lower court for further and appropriate proceedings.


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