KINDS OF PLEA

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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.
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(PEOPLE VS. MADRAGA , 344
SCRA 628)

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 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, accused-appellant, 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 : Held: Yes. Although the records do not show that appellant entered his plea with the
proviso that a certain penalty be imposed upon him, this can be inferred from the arguments made
by his counsel during the hearing on December 2, 1996, and in the appellant’s brief filed by said
counsel, asking that appellant be entitled to the benefit of the plea.
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.

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(PEOPLE VS PAGAL 79 SCRA 570)

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 CASE

• Facts : Facts : Accused-appellants Pagal and Torcellino were charged with the crime of robbery
with homicide, with the generic aggravating circumstances of nightime purposely sought to
better accomplish their criminal design; evident premeditation; in disregard of the respect due
the offended party; and with abuse of confidence, the accused being then employees of the
offended party. 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. the denial of the accused of his conspiracy with his co-appellant cannot be given
credence in view of the clear and convincing confession of his guilt in his statement signed by
him before the police investigators several hours after the commission of the crime. Besides,
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, the requisite proofs having been
supplied by the accused himself. 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.
 NEGATIVE PLEA
• 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.

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( PEOPLE VS STRONG, 63 SCRA
133)

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 CASE

Facts : During the continuation of the arraignment of accused Stephen Douglas Strong, Judge
Occeña asked him of the stated facts in the information to which he would categorically answered
no.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 he 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 these acts attributed
to him, answering "no" every time to each and every 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. We thus, conclude that the decision of the lower court be
remanded for trial for a plea of guilty to be judicially acceptable
there must be a showing of full understanding of what is at stake.