G.R. No. 11555 - People vs Soliman

Oscar M. Documento was charged with two counts of rape under Article 335 of the Revised Penal Code, as amended by R.A. 7659, in separate informations:

Criminal Case No. 6899: rape of his daughter AAA on April 22, 1996 at Ochoa Avenue, Butuan City.
Criminal Case No. 6900: rape of his daughter AAA on October 15, 1995 at Barangay Antongalon, Butuan City.

At arraignment, Documento first pleaded not guilty, then changed to a plea of guilt; the RTC re-arraigned him and entered his guilty plea.

AAA testified that Documento molested her from age 10 (1989), impregnated her (birth in 1993), and repeatedly raped her—using force, threats to kill, and occurring in various relatives’ homes in Butuan City.
BBB (AAA’s mother) worked in Manila (1994–1996); upon learning of AAA’s pregnancy and whereabouts, she sought police help; after Documento’s arrest, AAA reported the rapes.
Dr. Johann A. Hugo conducted a genital examination: healed vaginal laceration, hymenal remnants (“caruncula multiforma”), two-finger admission, negative smear for spermatozoa.

Documento testified he pled guilty only because the prosecutor persuaded him; he denied rape, claiming a consensual relationship and that incidents occurred in Clarin, Misamis Occidental.
He disowned letters allegedly written by him to his wife and daughter asking forgiveness.

RTC (June 9, 2003) convicted Documento of both counts of rape, sentenced him to death for each, and awarded AAA ₱75,000 civil indemnity, ₱50,000 moral damages, and ₱25,000 exemplary damages per count.
CA (August 13, 2008) affirmed conviction, modified penalty to reclusion perpetua without parole, increased moral damages to ₱75,000 per count, retained exemplary damages at ₱25,000 per count.

Whether the RTC erred in deciding the case without first resolving its territorial jurisdiction over the crimes charged.
Whether the RTC erred in failing to conduct a searching inquiry into the voluntariness and full comprehension of Documento’s guilty plea.