Facts:

• Luisito Baun y Mercado was accused of qualified rape against his daughter, referred to as AAA.
• Four separate Informations for qualified rape were filed on January 15, 2002, for incidents occurring on July 21, August 9, August 15, and September 30, 2001.
• The victim was aged 13 and 14 during these incidents.
• Baun initially pleaded not guilty during his arraignment on April 15, 2002, but later sought to change his plea to guilty on July 22, 2002.
• The trial court conducted a brief inquiry into the voluntariness of his plea but did not adhere strictly to procedural guidelines.
• Evidence included the victim's testimony, a medical certificate showing hymenal lacerations, and the victim's birth certificate confirming her age and relationship to Baun.
• On August 12, 2002, the Regional Trial Court (RTC) convicted Baun of four counts of rape and sentenced him to death.
• The Court of Appeals modified the RTC's decision, affirming the conviction and imposing additional damages.
• The Supreme Court reviewed the case, focusing on the validity of Baun's guilty plea and the sufficiency of the evidence.

Issue:

• (Unlock)

Ruling:

• The Supreme Court affirmed the Court of Appeals' decision, upholding Baun's conviction for four counts of rape.
• The death penalty was modified to four counts of reclusion perpetua without eligibility for parole, in line with Republic Act No. 9346....(Unlock)

Ratio:

• The Supreme Court analyzed the procedural aspects of Baun's guilty plea, emphasizing the need for a thorough inquiry to ensure the plea is voluntary and fully understood.
• Despite the trial court's failure to strictly follow procedural guidelines, the evidence, particularly the victim's credible testimony and medical findings, established Baun's guilt beyond a reasonable doubt.
• The Court noted that in incestuous rape cases, a father's moral ascendancy can substitute for violenc...continue reading