People v. Durango | GR. No.

135438
FACTS: This case has reached the SC by an automatic review from the decision of the RTC of
Malabon of Death Penalty. Bonifacio Durango was charged with two counts of rape. During
arraignment, Durango entered a plea of not guilty. During the trial, Durangos defense counsel
manifested to the court that Durango wanted to withdrew his earlier plea of not guilty and substitute it
with a plea of guilty. On the basis of the manifestation, Durango was re-arraigned, and this time he
pleaded guilty. After the prosecution had concluded its presentation, the RTC rendered a decision
finding the accused guilty and sentencing him to death.
ISSUE: Whether the RTC erred in convicting Durango despite his improvident plea of guilty.
RULING: Yes. When an accused enters a plea of guilty, the trial court is mandated to see to it that the
exacting standards laid down by the rules therefore are strictly observed. It cannot be said that when a
person pleads guilty to a crime there is no chance at all that he could, in fact, be innocent. The
improvident plea, followed by an abbreviated proceeding, with practically no role at all played by the
defense is just too meager to accept as being the standard constitutional due process at work enough to
forfeit human life. The case was set aside and remanded to the trial court for further and appropriate
proceedings.