People v Holgado; G.R. No. L-2809; 22 Mar 1950; 86 Phil 752

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Appellant was charged with slight illegal detention. On the day of the trial, the trial court proceeded with the accused appearing without a lawyer, pleading guilty and submitting himself to the proceedings. Two days later, the trial court rendered a decision convicting the appellant.

Whether or not appellant validly waived his right to counsel during the trial.

NO. The right to be heard would be of little avail if it does not include the right to be heard by counsel. Even the most intelligent or educated man may have no skill in the science of the law, particularly in the rules of procedure, and, without counsel, he may be convicted not because he is guilty but because he does not know how to establish his innocence.

Judgment appealed from is REVERSED and the case is REMANDED to the trial court.

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