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PEOPLE VS DURANGO

April 5, 2000 | Vitug, J. | Automatic Review | Arraignment and Plea

PETITIONER: The People of the Philippines


RESPONDENT: Bonifacio Durango

SUMMARY: Accused entered a plea of not guilty to the two counts of rape. Thereafter, at trial, he manifested that he wanted to
enter a plea of guilty. This plea was accepted by the court. The prosecution the presented the witness and, without the defense
counsel having a chance to speak, the case was abruptly submitted for decision.

DOCTRINE: When an accused makes an improvident plea of guilty, the court MUST conduct a searching inquiry to ascertain if
the accused made the plea voluntarily and with comprehension.

FACTS: 1. When an accused makes an improvident plea of guilty, it is


1. Accused in this case was charged with two counts of rape. incumbent upon the court to make a searching inquiry
Initially, he entered a plea of not guilty but barely after the regarding the voluntariness of this plea. The reason is that,
prosecution presented its evidence and witnesses, the accused notwithstanding such plea, the accused may actually be
manifested that he wanted to enter a plea of guilty. innocent after all.
2. On the basis of this, the prosecution proceeded to present 2. After the manifestation to enter a plea of guilty, the court
testimony and then the trial court already rendered a decision issued a joint order directing the prosecution to present the
pronouncing the accused guilty of two counts of rape and complainant after accepting the plea of guilty.
sentencing him to death. 3. After presenting the complainant, the defense counsel was
not even able to speak one word when the case was suddenly
ISSUE/S: 1. Did the trial court err in convicting accused, submitted for decision already.
notwithstanding his improvident plea of guilty? - YES 4. Most troublesome is that the accused was not apprised of
the consequences of entering a plea of guilty. A searching
RULING: Decisions are SET ASIDE and case is inquiry is indispensable for determining 1) the voluntariness
REMANDED. of the plea; and 2) the comprehension of the accused in
making such plea.
RATIO: