Case Digest
Case Title: Salvador Estipona, Jr. y Asuela vs. Hon. Frank E. Lobrigo, Presiding Justice of the RTC Branch 3, Legazpi City, Albay and the People
Case Number: G.R. No. 226679
Date: August 15, 2017
Court: Supreme Court of the Philippines
Facts:
Salvador Estipona, Jr. y Asuela was charged with robbery in the Regional Trial Court (RTC) Branch 3 of Legazpi City, Albay. During the arraignment proceedings, Estipona refused to enter a plea, claiming that he had not received a copy of the Information filed against him. Despite the prosecution's insistence that Estipona was duly notified of the charges, the Presiding Justice of the RTC Branch 3, Hon. Frank E. Lobrigo, ordered the arraignment to proceed and entered a plea of not guilty on Estipona's behalf.
Issue:
The main issue in this case is whether the trial court's decision to proceed with the arraignment and enter a plea of not guilty on the accused's behalf, despite his protestation of not receiving a copy of the Information, was valid and in accordance with Rule 116 of the Rules of Court.
Ruling:
The Supreme Court ruled in favor of Salvador Estipona, Jr. y Asuela. The Court held that under Rule 116 of the Rules of Court, an accused has the right to be informed of the nature and cause of the accusation against him before he can be arraigned. In this case, Estipona's claim of not receiving a copy of the Information raised a substantial question regarding the validity of the arraignment. The trial court should have verified the accused's claim and ensured that he was properly notified of the charges before proceeding with the arraignment. Therefore, the Supreme Court declared the arraignment and plea entered on behalf of Estipona as null and void, and ordered the trial court to conduct a proper arraignment in accordance with the rules.
PH