86 People v. Baharan

86 People v.
Baharan
G.R. No. 188314. January 10, 2011, J. Sereno
TOPIC: R.116:Effect of Improvident Plea of Guilty
DOCTRINE/S:
 Convictions based on an improvident plea of guilt are set aside only if such plea is the sole basis of the judgment.
 If the trial court relied on sufficient and credible evidence to convict the accused, the conviction must be sustained, because then it is
predicated not merely on the guilty plea of the accused but on evidence proving his commission of the offense charged.

FACTS:
1. An RRCG bus was plying its usual southbound route two men boarded it. The bus conductor became wary of the two who sat away from
each other. At the time, there were only 15 passengers inside the bus. He also noticed that the eyes of one of the men were reddish.
2. As soon as the bus reached the stoplight at the corner of Ayala Avenue and EDSA, the two men insisted on getting off the bus. According to
Andales, the bus driver initially did not want to let them off the bus, because a Makati ordinance prohibited unloading anywhere except at
designated bus stops.
3. Eventually, the bus driver gave in and allowed the two passengers to alight. Moments after, Andales felt an explosion. He then saw fire
quickly engulfing the bus. He ran out of the bus towards a nearby mall. After a while, he went back to where the bus was. He saw their bus
passengers either lying on the ground or looking traumatized.
4. In the light of the pre-trial stipulations, the trial court asked whether accused Baharan and Trinidad were amenable to changing their "not
guilty" pleas to the charge of multiple frustrated murder, considering that they pled "guilty" to the heavier charge of multiple murder,
creating an apparent inconsistency in their pleas.
5. Defense counsel conferred with accused Baharan and Trinidad and explained to them the consequences of the pleas. The two accused
acknowledged the inconsistencies and manifested their readiness for re-arraignment. After the Information was read to them, Baharan and
Trinidad pled guilty to the charge of multiple frustrated murder.
6. After being discharged as state witness, accused Asali testified that while under training with the Abu Sayyaf, Rohmat, a.k.a Abu Jackie or
Zaky, and two other persons taught him how to make bombs and explosives. The trainees were told that they were to wage battles against
the government in the city, and that their first mission was to plant bombs in malls, the Light Railway Transit (LRT), and other parts of Metro
Manila.
7. As found by the trial court, Asali, after his training, was required by the Abu Sayyaf leadership, to secure materials which he knew would be
used to make a bomb. The TNT was allegedly placed in two buses sometime in December 2004, but neither one of them exploded.
8. Asali then testified that the night before the Valentine’s Day bombing, Trinidad and Baharan got another TNT from him. Late in the evening
of 14 February, he received a call from Abu Solaiman. The latter told Asali not to leave home or go to crowded areas, since the TNT taken
by Baharan and Trinidad had already been exploded in Makati. Trinidad called Asali, repeating the warning of Abu Solaiman. The next day,
Asali allegedly received a call from accused Rohmat, congratulating the former on the success of the mission.
9. 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."
ISSUE/S:
1. WON the trial court erred in accepting the accussed-appellants’ plea of guilt despite insufficiency of searching inquiry.
2. WON the guilt of the accused-appellants has been proven beyond reasonable doubt.
HELD:
1. Court deemed it unnecessary to rule on the sufficiency of the searching inquiry in this case since the accused previously pled guilty to
another charge (multiple murder) based on the same act relied upon in the multiple frustrated murder charge.
 The stringent procedure governing the reception of a plea of guilt, especially in a case involving the death penalty, is imposed upon the trial
judge in order to leave no room for doubt on the possibility that the accused might have misunderstood the nature of the charge and the
consequences of the plea.
 The requirement to conduct a searching inquiry applies more so in cases of re-arraignment. In People v. Galvez, the Court noted that since
accused-appellant’s original plea was “not guilty”, the trial court should have exerted careful effort in inquiring into why he changed his plea
to “guilty”.
 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.
 However, the Court observes that accused Baharan and Trinidad previously pled guilty to another charge – multiple murder – based on the
same act relied upon in the multiple frustrated murder charge.
 The Court further notes that prior to the change of plea to one of guilt, accused Baharan and Trinidad made two other confessions of guilt
– one through an extrajudicial confession (exclusive television interviews, as stipulated by both accused during pretrial), and the other via
judicial admission (pre-trial stipulation).
 Considering this, the Court deemed it unnecessary to rule on the sufficiency of the “searching inquiry” in this instance.
 Remanding the case for re-arraignment is not warranted, as the accused’s plea of guilt was not the sole basis of the condemnatory
judgment under consideration.
2. YES. The guilt of the accused Baharan and Trinidad was sufficiently established by these corroborating testimonies, coupled with their
respective judicial admissions (pretrial stipulations) and extrajudicial confessions (exclusive television interviews, as they both stipulated
during pretrial) that they were indeed the perpetrators of the Valentine's Day bombing.
In People v. Oden, the Court declared that even if the requirement of conducting a searching inquiry was not complied with, "[t]he manner by
which the plea of guilt is made . . . loses much of great significance where the conviction can be based on independent evidence proving the
commission by the person accused of the offense charged.
Convictions based on an improvident plea of guilt are set aside only if such plea is the sole basis of the judgment. If the trial court relied on
sufficient and credible evidence to convict the accused, the conviction must be sustained, because then it is predicated not merely on the guilty
plea of the accused but on evidence proving his commission of the offense charged.
Here, the plea of guilty was NOT the sole basis of judgement. The prosecution was able to present evidence, primarily testimonies of the bus
conductor and Asali (accused turned state witness).
• Andales positively identified accused Baharan and Trinidad as the two men who had acted suspiciously while inside the bus; who had insisted
on getting off the bus in violation of a Makati ordinance; and who had scampered away from the bus moments before the bomb exploded.
• Asali testified that he had given accused Baharan and Trinidad the TNT used in the bombing incident in Makati City.
• The guilt of the accused Baharan and Trinidad was sufficiently established by these corroborating testimonies, coupled with their respective
judicial admissions (pretrial stipulations) and extrajudicial confessions (exclusive television interviews, as they both stipulated during
pretrial) that they were indeed the perpetrators of the Valentine's Day bombing
PETITION IS DENIED.

86 People v. Baharan

Uploaded by

Copyright:

Available Formats

86 People v. Baharan

Uploaded by

Document Information

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

86 People v. Baharan

Uploaded by

Copyright:

Available Formats

86 People v.

You might also like