G.R. No. 147965 - People vs. Apatay y Balo

The case involves the conviction of Rey Apatay y Balo for rape with homicide, an offense that occurred on or about October 20, 2000, in Sikatuna, Bohol.
The accused was charged under Articles 266-A and 266-B of the Revised Penal Code (as amended by R.A. 7659) for having carnal knowledge of the victim, Catalina Baluran—by force, threat, or intimidation—and subsequently killing her by inflicting fatal injuries.
The Regional Trial Court (RTC), Branch 2, Tagbilaran City, rendered its decision on March 5, 2001, sentencing the accused to death and ordering him to indemnify the heirs of the victim for P100,000.00.

During arraignment, the Information was read in the defendant’s native Visayan dialect, ensuring that he fully understood the charges against him.
The accused, assisted by counsel from the Public Attorney’s Office, entered a plea of guilty and underwent a searching inquiry, where the court confirmed that his plea was voluntary and that he comprehended its consequences—including the imposition of the death penalty.
Following the plea, the trial court directed the prosecution to present evidence to establish the accused’s guilt and the precise degree of his culpability.

Witnesses such as Francisca Buchan and Odelion Manco testified regarding observations made on the day of the incident, including:

Noticing the accused standing near the victim’s house before the crime.
Observing a chaotic scene the following morning when the victim could not be found and evidence of violence (drops of blood and a piece of firewood) was discovered inside the house.

A post-mortem examination conducted by Dr. Francisco Romulo D. Villaflor revealed multiple injuries on Catalina Baluran, including:

Skull fractures, lacerations, and ecchymoses.
Vaginal lacerations at different clock positions, indicating a forcible sexual assault.
A massive hemorrhage as the cause of death.

The accused’s extra-judicial confession, executed in the Visayan dialect and later translated into English, provided detailed admission of the commission of the rape-slay, including:

His method of entering the victim’s house, switching off the light, and forcibly abducting and sexually assaulting her.
His subsequent actions—choking Catalina, striking her with a piece of firewood, and disposing of her body in an abandoned toilet.
An admission that he helped in the search for the victim, which coincided with his growing conscience regarding the crime.

The RTC, after conducting a searching inquiry to ascertain the voluntariness of the plea, found the accused guilty beyond reasonable doubt based on:

The spontaneous and categorical admissions in his extra-judicial confession.
Corroborative testimonies from eye-witnesses and the forensic evidence presented in the post-mortem report.

In line with the provisions of Articles 266-A and 266-B of the Revised Penal Code, the trial court imposed the supreme penalty of death on the accused.
The decision also required the accused to pay indemnity to the heirs of the victim, covering both rape and the subsequent death, with additional awards for moral and temperate damages.

The appellant argued that the trial court’s inquiry failed to adequately confirm:

Whether his plea of guilty was both voluntary and comprehensively made with full knowledge of its consequences.
Whether he was afforded the opportunity to present evidence in his defense, despite his plea.

The defense’s contentions were countered by the Solicitor General, who maintained that:

The trial court conducted the prescribed searching inquiry as mandated by Section 3, Rule 116 of the Revised Rules of Criminal Procedure.
Appellant’s plea was made voluntarily, and the subsequent evidence reinforced his guilt.

Ultimately, the defense opted not to present any additional evidence, relying on the comprehensive admissions contained in the confession and the witness testimonies.

Whether the trial court properly conducted a searching inquiry to confirm the voluntariness and full comprehension of the accused’s plea of guilty, especially given the grave consequence of a death sentence.

Does the record support that the accused was made aware of all the rights and consequences before entering his plea?

Whether the evidence, including the extra-judicial confession and corroborative testimonies, sufficiently established the accused’s guilt beyond a reasonable doubt for the crime of rape with homicide.

Were the forensic and testimonial evidences reliably interconnected to prove both the act and the intent of the offense?

Whether the imposition of the death penalty under Articles 266-A and 266-B of the Revised Penal Code was proper, given the established elements of the offense.

Can the application of the "single, indivisible penalty" rule justify the severity of the sentence even in the presence of mitigating arguments?

Whether the awarded collateral relief to the victim’s heirs (civil indemnity, moral damages, and temperate damages) was properly determined based on the evidence presented.