Case Digest (G.R. No. 172868)
Facts:
People of the Philippines v. Roberto Aguilar, G.R. No. 172868, March 14, 2008, the Supreme Court En Banc, Carpio Morales, J., writing for the Court.The accused-appellant is Roberto Aguilar; the victim is identified in the record as AAA (name withheld). On May 4, 2003 AAA, then 14 years old, alleged that at about 2:00 a.m. her father, Roberto Aguilar, entered the room where she and her younger sister CCC were sleeping, undressed her, lay atop her, inserted his penis into her vagina and committed forcible sexual intercourse while threatening her with a knife. CCC feigned sleep but observed the incident and later reported it to their aunt DDD, who, after consulting her husband, accompanied AAA to the Taguig Police Station to file a complaint. A medico-legal examination described the hymen as showing healed lacerations and concluded the subject was in a "non-virgin state physically."
Appellant was charged by information with Qualified Rape (Criminal Case No. 125621-H). On arraignment appellant initially told the trial court he intended to plead guilty; arraignment occurred on July 21, 2003, when he pleaded guilty. The trial court conducted a searching inquiry into voluntariness and comprehension, then required the prosecution to present evidence to prove guilt and degree of culpability; the prosecution presented AAA, CCC and DDD. After the prosecution rested, appellant declined to testify or present evidence in his defense.
By decision dated October 10, 2003, Branch 69 of the Regional Trial Court, Pasig City convicted appellant of Qualified Rape and imposed the death penalty, awarding moral, civil indemnity and exemplary damages. Because the penalty was capital, the case was subject to automatic review; following People v. Mateo the Supreme Court transferred the case to the Court of Appeals for intermediate review.
By Decision dated August 31, 2005 the Court of Appeals (CA-G.R. CR.-H.C. No. 01298) affirmed the trial court's conviction but modified the award of civil indemnity (increasing it). The case was then brought to the Supreme Court on petition for review of the Court of Appeals' decision. The Court required supplemental briefs (Resolution, July 11, 2006); none were filed.
The Supreme Court examined compliance with Section 3, Rule 116 of the Rules of Court governing a plea of guilty to a capital offense and the adequacy of the prosecution's evidence. The Court noted it had earlier articulated detailed guidelines for a searching inquiry in cases such as People v. Gumimba, People v. Tonyacao, People v. Pastor, People v. Aranzado, People v. Chua, People v. Alicando, and People v. Albert. While the trial court did not fully observe those guidelines, the Court found the prosecution's evidence sufficient to sustain conviction beyond reasonable doubt and observed that appellant had declined ...(Subscriber-Only)
Issues:
- Did the trial court comply with the requirements of Section 3, Rule 116 (the searching inquiry) when appellant pleaded guilty to a capital offense?
- Was the prosecution's evidence sufficient to prove beyond reasonable doubt that appellant committed Qualified Rape?
- What is the proper penalty in light of R.A. No. 9346 abo...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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