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    People v. Estomaca

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    MAC
    The Supreme Court ruled that the arraignment of the defendant was invalid for two reasons: 1) The complaint was not read to the defendant in a language he understood, as it was read in Ilonggo instead of his native dialect of kinaray-a; 2) The arraignment did not establish that the defendant's plea was made voluntarily and with full comprehension of the consequences, as required by Section 3 of Rule 116. As the arraignment was invalid, the subsequent judgment of conviction was also invalid and the case was remanded to the trial court for further proceedings.

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    People v. Estomaca

    Uploaded by

    MAC
    123 views2 pages
    The Supreme Court ruled that the arraignment of the defendant was invalid for two reasons: 1) The complaint was not read to the defendant in a language he understood, as it was read in Ilonggo instead of his native dialect of kinaray-a; 2) The arraignment did not establish that the defendant's plea was made voluntarily and with full comprehension of the consequences, as required by Section 3 of Rule 116. As the arraignment was invalid, the subsequent judgment of conviction was also invalid and the case was remanded to the trial court for further proceedings.

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    The Supreme Court ruled that the arraignment of the defendant was invalid for two reasons: 1) The complaint was not read to the defendant in a language he understood, as it was read in Ilonggo instead of his native dialect of kinaray-a; 2) The arraignment did not establish that the defendant's plea was made voluntarily and with full comprehension of the consequences, as required by Section 3 of Rule 116. As the arraignment was invalid, the subsequent judgment of conviction was also invalid and the case was remanded to the trial court for further proceedings.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    123 views2 pages

    People v. Estomaca

    Uploaded by

    MAC
    The Supreme Court ruled that the arraignment of the defendant was invalid for two reasons: 1) The complaint was not read to the defendant in a language he understood, as it was read in Ilonggo instead of his native dialect of kinaray-a; 2) The arraignment did not establish that the defendant's plea was made voluntarily and with full comprehension of the consequences, as required by Section 3 of Rule 116. As the arraignment was invalid, the subsequent judgment of conviction was also invalid and the case was remanded to the trial court for further proceedings.

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    © All Rights Reserved
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    of 2

    People v.

    Estomaca
    G.R. No. 117485-86 (April 22, 1996)

    Topic: Rule 116: Arraignment and Plea

    Issue: Whether or not the arraignment was valid

    Held: No

    Ratio: With exacting certitude, 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 knows 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.

    And, on this latter aspect, we are inclined to quote from Alicando since, as stated in limine the defective
    arraignment in the cases now before us is virtually a reprise of what the same trial court with its presiding
    judge did or did not do in that previous case:

    Section 3 of Rule 116 which the trial court violated is not a new rule for it merely incorporated the decision
    of this Court in People vs. Apduhan Jr. and reiterated in an unbroken line of cases. 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 appellant's 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.

    It will be readily observed, if one would analyze appellant's responses during his irregular arraignment that
    his low intelligence quotient and lack of education combined to deprive him of fully understanding what
    obviously appeared to him as mysterious rituals and unfamiliar jargons.

    Adverting once again to Alicando, we reiterated therein that pursuant to Binabay vs. People, et al., no
    valid judgment can be rendered upon an invalid arraignment. Since in Alicando the arraignment of
    appellant therein was void, the judgment of conviction rendered against him was likewise void, hence in
    fairness to him and in justice to the offended party that case was remanded to the trial court for further
    proceedings. The case at bar being on all fours with the aforementioned cases on the particular
    determinant issue, we have perforce to yield to the same doctrine and disposition.

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