GR 45354; (June, 1937) (Digest)
G.R. No. 45354 ; June 29, 1937
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DEOGRACIAS CARIAGA, defendant-appellant.
FACTS
The accused, Deogracias Cariaga, was convicted by the Court of First Instance of Manila for the crime of theft. The trial court’s judgment stated that upon arraignment, he entered a plea of guilty. He was sentenced to one month and one day of arresto mayor, an indemnity, and an additional penalty as a habitual delinquent. On appeal, the accused argued that the record did not show the details of his arraignment or that he was advised of his right to counsel.
ISSUE
Whether the trial court committed reversible error in convicting the accused based on its judgment’s statement that he pleaded guilty upon arraignment, despite the lack of detailed minutes recording the arraignment and plea.
RULING
No. The Supreme Court affirmed the conviction but modified the penalty. The Court held that the trial judge’s positive statement in the judgment that the accused was arraigned and pleaded guilty is sufficient compliance with the law. It is immaterial whether such facts appear in the minutes or in the judgment itself. The presumption that the law was obeyed applies. Regarding the right to counsel, the absence of an affirmative record that the judge advised the accused of this right does not constitute reversible error. However, the Court found the allegations for habitual delinquency insufficient under existing doctrine and instead considered the mitigating circumstance of a plea of guilty. The penalty was modified to two months and one day of arresto mayor. A subsequent motion for reconsideration by the accused, which challenged the truth of the judge’s statement, was denied as unfounded and imprudent.
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