KINDS OF PLEA

RULE 116 ARRAIGNMENT AND PLEA

CONDITIONAL PLEA
a conditional plea of guilty or one entered
subject to the proviso that a certain
penalty be imposed upon him.
It is equivalent to a plea of not guilty.
It would re quire a full-blown trial before
judgment may be rendered.
RULE 116 ARRAIGNMENT AND PLEA

(PEOPLE VS. MADRAGA , 344

SCRA 628)

RULE 116 ARRAIGNMENT AND PLEA

CASE
Facts :
Rodolfo Oling Madraga was charged with two (2) counts of rape
committed against his own 16-year old daughter, Fe C.
Madraga.. At the arraignment on November 4, 1996, accusedappellant, with the assistance of Atty. Antonio D. Banico, entered
separate pleas of not guilty for each case. On November 18,
1996, Atty. Banico, counsel for the accused, moved that they be
given time up to December to talk with complainant mother so
that the accused will plead guilty to the first case, but will seek
for the dismissal of the second case.

CASE

Issue : whether or
not the plea of the
accused valid?

CASE
Held : Yes. Accused-appellant entered a plea of guilty, but it appears from the records
of the proceedings before the court a quo that the same was a conditional plea,
because appellants counsel argued that the mitigating circumstances of plea of guilty
and drunkenness should be appreciated in favor of the appellant.Said counsel was
apparently unaware that the mitigating circumstances of plea of guilty, and the fact
that the appellant was drunk when he committed the crime, cannot be appreciated in
the latters favor because a plea of guilty would not, under any circumstance, affect
or reduce the death sentence. We would, thus, assume that appellant made a
conditional plea because this assumption would be more favorable to the accused. A
conditional plea of guilty, or one entered subject to the provision that a certain
penalty be imposed upon him, is equivalent to a plea of not guilty and would,
therefore, require a full-blown trial before judgment may be rendered.

UNCONDITIONAL PLEA
a plea of guilty is an unconditional plea of guilt
with respect to the offense charged.
It forecloses the right to defend oneself from
said charge and leaves the court with no
alternative but to impose the penalty fixed by
law under the circumstances.
It includes the aggravating circumstances
therein specified.
RULE 116 ARRAIGNMENT AND PLEA

(PEOPLE VS PAGAL 79 SCRA 570)

RULE 116 ARRAIGNMENT AND PLEA

CASE
Facts : The accused, Pedro Pagal and Jose Torcelino were charged with the crime of robbery with
homicide.the said accused, conspiring and confederating together and mutually helping each other,
did then and there wilfully, unlawfully and feloniously, with intent to gain, and by means of violence,
take away from the person of one Gau Guan, cash amounting Pl,281.00. Philippine currency, to the
damage and prejudice of the said Gau Guan in the said sum of Pl,281.00; that on the occasion of the
said robbery and for the purpose of enabling them to take, steal and carry away the said amount of
P1,281.00, the herein accused, in pursuance of their conspiracy, did then and there wilfully, unlawfully
and feloniously, with intent to kill and taking advantage of their superior strength, treacherously
attack, assault and use personal violence upon the said Gau Guan, by then and there stabbing him
with an icepick and clubbing him with an iron pipe on different parts of his body, thereby inflicting upon
him mortal wounds which were the direct and immediate cause of his death thereafter. When case was
called for arraignement the counsel of the accused informed the court with their intention to enter a
plea of guilty with the proviso that they may be allowed to prove the mitigating circumstances.

CASE
Issue : whether or not the plea
of the accused valid?

CASE
Held : Yes, when he pleaded guilty to the charge, he is deemed to have
admitted all the material facts alleged in the information. By his plea, the
appellant admitted not only the commission of the crime but also the
circumstances surrounding its commission, including the allegations of
conspiracy. A plea of guilty when formally entered on arraignment, is
sufficient to sustain a conviction even for a capital offense without the
introduction of further evidence, 9 the requisite proofs having been supplied
by the accused himself. 10 We find, therefore, that the trial court did not
commit any error in convicting the appellant Pedro pagal of the crime of
robbery with homicide.

N E G ATI V E P L E A
It is an ambiguous or indefinite plea of
guilt.
A plea that will deny the substantial
charges and specify a fact that will make
the position of the plaintiff untenable.
RULE 116 ARRAIGNMENT AND PLEA

( PEOPLE VS STRONG, 63 SCRA

133)

RULE 116 ARRAIGNMENT AND PLEA

CASE
Facts : During the continuation of the arraignment, the accused Stephen Douglas Strong
was asked by Judge Occena "And it is also stated here, "that on the occasion and in
pursuance of said robbery and to ensure his felonious intent, the above-named accused
with intent to kill, with treachery and evident premeditation, did then and there willfully,
unlawfully and feloniously, with the use of a fork and towel, attack, assault, stab, choke
and strangle one Cornelia Bartolaba, which caused her immediate death", what do you
say to that? 2 His categorical answer: "No." 3 Then when interrogated further to explain
why he answered in the negative considering that he had entered a guilty plea and
specifically queried as to whether he meant to say that he did not attack, that he did not
assault, that be did not stab, that he did not choke and strangle the victim, Cornelia
Bartolaba, to death, there was an outright denial that he did any of those acts attributed
to him, answering "no" every time to each and ever question.

CASE
Issue : whether or not the plea
of the accused valid?

CASE
Held : No, The element of fairness cannot be satisfied in any other manner. There must
be, for a plea of guilty to be judicially acceptable then, a showing of full understanding of
what is at stake. That is so even when an accused does clearly admit the commission of
the culpable act. Here, on the contrary, while there was an admission of guilt hastily
made, it turned out, on his being specifically questioned, the accused denied most
categorically the allegations in the information.It is indeed deplorable, considering that
as of the time the trial judge decided the case, this Court had reiterated Apduhan in no
less than twenty-nine separate occasions, that he did act the way he did, apparently
heedless of what is authoritatively ordained time and time again. Even a cursory perusal
of this Court's decisions should make clear the undeviating adherence to such a basic
doctrine. Judicial carelessness, it thus appears, has never been carried before to such
extremes. It ought never to have happened, and care should be taken that it does not
happen again.