Case Digest (G.R. No. 119073)
Facts:
People of the Philippines v. Alberto Diaz, G.R. No. 119073, March 13, 1996, the Supreme Court En Banc, Puno, J., writing for the Court.In an Information dated November 16, 1994 (Criminal Case No. 12088, RTC of Palawan and Puerto Princesa City, Branch 49, presided by Judge Eustaquio Gacott, Jr.), Alberto Diaz (accused-appellant) was charged with the capital crime of rape under Article 335 of the Revised Penal Code as amended by R.A. 7659 for having carnal knowledge of his 14‑year‑old daughter, Dorileen Diaz, allegedly against her will. Arraignment and pretrial were set for January 13, 1995. The accused was represented by Atty. Lucia Judy Solinap of the Public Attorneys Office; prior to arraignment defense counsel informed the court that accused intended to plead guilty to avoid litigation expenses.
At arraignment held in Tagalog, accused pleaded guilty. The trial court placed him on the witness stand to determine whether he fully comprehended the consequences of his plea. Accused (a 41‑year‑old farmer) admitted raping his daughter twice, stated that he understood the Information and that his plea was voluntary, but during questioning he vacillated, at one point saying he “could not do anything” but plead guilty and later saying he did not know the consequences. He testified he had been arrested on October 3, 1994 and detained for five months; he appeared coherent and aware of the penalty (death) for the offense.
Convinced by the accused’s admissions, and without requiring the prosecution to present testimonial or documentary evidence proving the elements of the offense and the precise degree of culpability, the trial court convicted him and imposed the death penalty. Accused did not file an appeal; however, because the penalty imposed was death, the judgment was elevated to the Supreme Court for automatic review. In his brief filed by PAO, accused contended that the trial court erred in convicting ...(Subscriber-Only)
Issues:
- Did the trial court comply with Section 3, Rule 116 of the Rules on Criminal Procedure after the accused pleaded guilty to a capital offense?
- Can a conviction and imposition of the death penalty rest solely on an accused’s plea of guilty where the trial court failed to require the prosecution to prove guilt and degree of culpability and the plea showed signs of vacill...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
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Doctrine:
- (Subscriber-Only)