People Vs Sta Teresa

G.R. No.
130663 March 20, 2001
PEOPLE OF THE PHILIPPINES, appellee,

vs.
ANGELES STA. TERESA, appellant.
Facts:
Angeles Sta. Teresa was found guilty beyond reasonable doubt of raping his 12-year old daughter and imposing
upon him the supreme penalty of death. When arraigned Sta. Teresa pleaded not guilty with the assistance of his counsel
de oficio. But after the prosecution presented its witnesses medico-legal officer, and the rape victim, Sta. Teresa withdrew
his plea of "not guilty" and changed it to a plea of "guilty." After such manifestation, Sta. Teresa’s counsel did not make
any comment or objection against documentary exhibit of prosecution. Sta. Teresa even testified how the rape occurred.
The trial court, after evaluating the prosecution evidence and considering appellant's admission of the crime, convicted
him of rape and sentenced him to death.
Issue:
Whether or not of RTC correctly held finding Sta. Teresa guilty base on his plea of guilty
Held:
No. The court hold that the abbreviated and aborted presentation of the prosecution evidence and appellant's
improvident plea of guilty, with the scanty and lackluster performance of his counsel de oficio, are just too exiguous to
accept as being the standard constitutional due process at work enough to snuff out the life of a human being.
1. As to the judgement base on Sta. Teresa,s plea :
As discussed, Sta. Teresa initially entered a plea of "not guilty." However, after the victim and the medico-legal
officer testified against him, his counsel de oficio manifested that his client wanted to change his plea of "not guilty" to one
of "guilty."
The trial judge then conducted an inquiry into the voluntariness of the change of plea and appellant's full
comprehension of its consequences. However, we believe that the trial judge fell short of the exacting standards set forth
in Section 3, Rule 116 of the Revised Rules of Criminal Procedure, as follows:
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 present evidence in his behalf.
As can be gleaned from this Rule, the trial court must, if the accused pleads guilty to a capital offense, first,
conduct a searching inquiry into the voluntariness of the plea and the accused's full comprehension of the consequences
thereof; second, require the prosecution to present evidence to prove the guilt of the accused and the precise degree of
his culpability; and third, ask the accused if he desires to present evidence on his behalf and allow him to do so if he
desires.
The trial court asserts that it has conducted a searching inquiry into the voluntariness of his plea of "guilty." We
are not persuaded.
As explained in People v. Alicando,16 a searching inquiry occurs when the plea of guilt is based on a free and
informed judgment, focusing on the voluntariness of the plea and the full comprehension of the consequences.
As to the conduct of Sta. Teresa’s counsel de oficio:
As exemplified in People v. Bermas:18
"x x x The right to counsel proceeds from the fundamental principle of due process which basically means that a
person must be heard before being condemned. The due process requirement is a part of a person's basic rights; it is
not a mere formality that may be dispensed with or performed perfunctorily.
"The right to counsel must be more than just the presence of a lawyer in the courtroom or the mere propounding of
standard questions and objections. The right to counsel means that the accused is amply accorded legal assistance
extended by a counsel who commits himself to the cause for the defense and acts accordingly. The right assumes an
active involvement by the lawyer in the proceedings, particularly at the trial of the case, his bearing constantly in mind
of the basic rights of the accused, his being well-versed on the case, and his knowing the fundamental procedures,
essential laws and existing jurisprudence. The right of an accused to counsel finds substance in the performance by
the lawyer of his sworn duty of fidelity to his client. Tersely put, it means an efficient and truly decisive legal
assistance and not a simple perfunctory representation."
The Court believe that the defense counsel's conduct falls short of the commitment and zeal required of him as
appellant's attorney. Barely nine (9) days after appellant pleaded "not guilty" to the crime charged, his counsel de oficio
made a manifestation in open court that his client is changing his plea to that of "guilty."
Considering the gravity of the offense charged and the finality of the penalty, the court find Atty. Adriano's
performance as counsel de oficio utterly wanting. As a lawyer sworn to uphold justice and the law, he had the bounden
duty to exert utmost efforts to defend his client and protect his rights, no matter how guilty or evil he appears to be. This
duty becomes more compelling if his client is accused of a grave crime and is in danger of forfeiting his life if he is
convicted.
The RTC decision is set aside and the case is remanded for further proceedings.

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G.R. No.

130663 March 20, 2001

PEOPLE OF THE PHILIPPINES, appellee,

1. As to the judgement base on Sta. Teresa,s plea :

As to the conduct of Sta. Teresa’s counsel de oficio:

As exemplified in People v. Bermas:18

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