G.R. No. 131814 - People vs. Arizapa

The accused, Rodolfo Arizapa, was charged with incestuous rape of his stepdaughter, Rosita Encinas, a 12-year-old minor.
The crime occurred on the evening of June 4, 1995, in Barangay Malatap, Labo, Camarines Norte.
The complainant, Rosita Encinas, was residing with her younger siblings at the time of the incident; her mother was in Manila.

Around midnight on June 4, 1995, while Rosita and her siblings were asleep, the accused entered their room.
Rosita, already asleep, was awakened when her stepfather—whom she addressed as “Papa Rudy”—approached her.
The accused, attired in shirt and shorts (without underwear), instructed her to lie down and cautioned her not to shout.
He proceeded to remove her shorts and panty, restrained her by holding her thighs, and threatened further harm should she cry out.
Subsequently, he undressed himself, climbed on top of her, separated her thighs, and inserted his penis into her vagina, causing her pain though no bleeding was noted.

The prosecutorial evidence included the victim’s direct and detailed testimony regarding the assault.
Medical evidence was presented by Dr. Marcelito Abas, who documented hematoma, slight genital swelling, and hymenal lacerations at multiple clock positions.
The victim’s account was corroborated by her aunt Flora Sena, who provided additional familial and chronological clarification regarding Rosita’s age.
The accused’s own testimony was recorded wherein he admitted, albeit with certain hesitations and after questioning, to raping his stepdaughter.
The record shows that the evidence was extensively elicited and was central to establishing the guilt of the accused.

The trial court found the accused guilty based on both his admission and the corroborative evidentiary details presented by the prosecution.
Although the defense raised the issue that the required searching inquiry into the voluntariness and full comprehension of the plea (as mandated by Sec. 3, Rule 116, of the 1985 Rules on Criminal Procedure) was not properly conducted, this argument was addressed in relation to the overwhelming evidence.
The accused had pleaded not guilty during arraignment and trial proceedings but eventually admitted his guilt after the prosecution rested its case.

The trial court ordered the accused to pay the victim moral damages of ₱50,000.00 and exemplary damages of ₱30,000.00.
However, based on applicable laws that require enhanced civil indemnity in rape cases committed under aggravating circumstances, the indemnity was later increased to ₱75,000.00.

Whether the trial court erred by failing to conduct a “searching inquiry” into the accused’s plea of guilt pursuant to Sec. 3, Rule 116 of the 1985 Rules on Criminal Procedure.
Whether the absence of such inquiry diminished the voluntariness and full comprehension of the accused’s plea.

Whether the evidence presented—comprising the victim’s testimony, the medical report, and the admissions of the accused—sufficiently established the guilt of the accused beyond any reasonable doubt.
Whether an improvident plea of guilt would constitute grounds for setting aside the conviction if it were the sole basis for the verdict.

Whether the imposition of the death penalty, as mandated by law when the crime is committed with qualifying aggravating circumstances, was proper.
Whether the award for civil indemnity should be increased in accordance with the applicable provisions of RA 7659 as amended by RA 8353.