People v. Strong
G.R. No. L-38626 March 14, 1975

Facts: 

Accused Strong pleaded guilty when arraigned. During the continuation of the arraignment, the asked what he could say to the allegation that he, 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." He categorically answered: "No." When interrogated further to explain why he answered in the negative considering that he had entered a guilty plea, there was an outright denial that he did any of those acts attributed to him, answering "no" every time to each and ever question. The trial court convicted Strong of the crime charged. 


Held: 

It is clear that the accused denied the allegations contained in the information. It is well-settled that when a plea of guilty is not definite or ambiguous, or not absolute, the same amounts to a plea of not guilty.

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. How could the plea of guilt earlier made be the basis of a judgment of conviction?