People v Estomaca (Melchor Estomaca y Garque) April 22, 1996 Regalado, J.

Under Arraignment; Nature and Purpose Short version: 5 complaints filed against Estomaca for committing rape and sexual assault against his daughter. In his arraignment, he pleaded guilty to all 5 cases, but he contradicted himself by saying that he only committed 2 out of the 5 offenses. Court found that lower court improperly followed the procedures regarding arraignment. Judgment of conviction for the 2 cases was reversed and they were remanded to the lower courts. How it reached the Supreme Court: Facts: Estomaca is an illiterate laborer charged with raping his own daughter Estelita. 5 complaints were filed and 2 of them are being challenged in this appellate review. The 2 instances which are the subject of the complaints happened on December 1993 and March 6, 1994. They both took place inside their residence in Iloilo. Lower court imposed penalty of RP for sexual assault in 1993, and Death for rape allegedly committed in 1994. From a perusal of the records of the case, it appears that the procedural rules to be observed for the validity of the arraignment of the accused were irregularly complied with; similar to what happened in the case of Alicando. o Estomaca claims to have performed only 2 out 5 cases filed against him, but he pleaded guilty to all 5 cases. This shows that the accused did not really understand the consequences of his actions during the arraignment. Issue: WON Estomacas arraignment was valid. (NO) [People v Albert]: Rationale behind the rule governing pleas of guilty to a capital offense is that courts must proceed with more care where possible punishment is death because execution of such sentence is irrevocable and experience has shown that innocent persons have at times pleaded guilty. Improvident pleas of guilt have to be avoided because the accused may forfeit his life and liberty without having fully understood the meaning, significance, and consequences of his plea. Section 1(a) of Rule 116 requires that: 1. 2. 3. 4. Arraignment should be made in open court by judge or by clerk of court The accused be furnished a copy of complaint or information with list of witnesses stated therein Reading of complaint or information in the language or dialect that is known to him (mandatory requirement) Asking him what his plea is to the charge 5 separate complaints (for 5 separate instances of rape and sexual assault) were filed in RTC Iloilo City against Estomaca. Only 2 complaints are being challenged in this case. Estomaca waived presentation of evidence for defense. Court required prosecution to establish Estomacas guilt beyond reasonable doubt. Estelita, the complainant, appeared and testified in court. Lower court imposed penalty of RP for sexual assault and Death for penalty of death for rape. Automatic review by Supreme Court (not indicated in the case, but it seems the most logical)

The arraignment is an avenue for the accused to be informed of the precise nature of the accusation against him and allows him to be able to hoist the necessary defense in rebuttal thereof. This is an integral aspect of the due process clause.

The transcript of the arraignment shows that it merely consisted of the bare reading of the five complaints. It was reported in the transcript that: Reading the information/complaint to the accused in Ilonggo/local dialect.

Since it was stated in the singular, Court speculates whether all five criminal complaints were actually read, translated or explained to Estomaca on a level within his comprehension considering his limited education.

It is apparent that there was irregularity in the arraignment because after the accused pleaded guilty to the 5 complaints, he subsequently stated that he wasnt guilty of the 3 cases filed against him.

Conducting the mechanical process of arraignment as outlined in Section 1 does not mean that there was the necessary degree of compliance by the court below. Other considerations reveal how flawed the arraignment was: 1. 2. 3. No showing WON Estomaca or his counsel de oficio was furnished copy of each of complaint with list of witnesses against him, in order that he may duly prepare and comply with his responsibilities. Estomaca was not warned that on his plea of guilty, he would definitely be given the death penalty under RA 7659 Estomaca was not advised that his plea of guilty would not affect or reduce the death sentence as he may have believed or have been erroneously advised.
*People v Dayot+: Searching inquiry means more than informing cursorily that accused faces a jail term, but also the exact length of imprisonment and the certainty that he will serve time at the national penitentiary or a penal colony. Not infrequently, accused pleads guilty in the hope of a lenient treatment, or upon a bad advice or promises of the authorities or parties of a lighter penalty should he express remorse. It is the duty of the judge that he does not labor under these mistaken impressions.

4.

The fact that complaints were supposedly read to appellant in Ilonggo/local dialect.
No statement that Estomaca understood it. Ilonggo/Hiligaynon is a regional language. In the place where the offenses were committed and where Estomaca was staying, the local dialect is kinaray-a. Such dialect is not readily understandable to those who speak Hiligaynon and vice versa.

Since all complaints are not only in English but in technical legal language, the Court doubts whether and how indictments were translated to Ilonggo and/or kinaray-a or that Estomaca was truly made aware of the consequences of his guilty plea.

Court must fully discharge duty to conduct the requisite searching inquiry to show that accused had not only made a clear, definite, and unconditional plea, but that he did so with a well-informed understanding and full realization of consequences. o Asking accused about his educational attainment and warning him that he might have admitted the crime because of his poor intelligence is not the logical approach in making sure that his plea of guilty is sufficient.

No definite and concrete rule of how trial judge may go about the matter of a proper searching inquiry, but it is advisable to require accused to fully narrate incident or by making him reenact manner of perpetrating crime, or by causing him to furnish and explain to the court the missing details of significance.

[People v Apduhan]: Searching inquiry of trial court must be focused on: (1) voluntariness of plea; and (2) full comprehension of consequences of his plea o In this case, it is clearly shown through his responses that accused didnt reall y know what was happening due to his lack of education and low intelligence. His answers were neither responsive nor rational.

[Alicando v People]: no valid judgment can be rendered upon an invalid arraignment.

1. 2. Since the arraignment was void, the judgment of conviction was likewise void; and in justice to the offended party, the case was remanded to trial court for further proceedings. Current case is on all fours with Alicando, therefore, it should be disposed in the same manner.

Judgment of Conviction in the 2 criminal cases SET ASIDE. Cases REMANDED to trial court. Digest Made by: Krys Martinez