Case Digest (G.R. No. 137256-58)
Case Digest (G.R. No. 137256-58)
Facts:
The People of the Philippines v. Rufino Ernas y Villanueva, G.R. Nos. 137256-58, August 06, 2003, the Supreme Court En Banc, Austria‑Martinez, J., writing for the Court. Appellant Rufino Ernas y Villanueva (accused) was charged in three separate Informations filed October 27, 1998 with rape of his daughters — complaint in Criminal Case No. 6178‑98‑C (victim AAA, 14 years old) and Complaints in Criminal Cases Nos. 6179‑98‑C and 6180‑98‑C (victim BBB, 15 years old). The Regional Trial Court (RTC), Calamba, Laguna, Branch 34, presided by Judge Antonio M. Eugenio, Jr., conducted pre‑trial, arraignment and re‑arraignment proceedings, and on January 14, 1999 rendered a joint judgment finding appellant guilty of three counts of rape and sentencing him to death for each count.At initial arraignment on November 13, 1998, appellant pleaded not guilty with counsel Atty. Rodel Paderayon. A joint pre‑trial order dated December 9, 1998 stipulated certain facts (paternity, existence of medico‑legal certificates and sworn statements, identity of accused), but admitted no prosecution facts. On January 13, 1999, with new counsel Atty. Eloida Capuno, appellant sought to withdraw his not guilty plea and, after re‑arraignment in Tagalog, entered separate pleas of guilty to each count; the RTC questioned him briefly and accepted his plea. The prosecution, having dispensed with the direct testimony of the complaining witnesses, offered documentary exhibits (complaints, sworn statements, medico‑legal certificates) which the RTC accepted and upon which it convicted and sentenced appellant on January 14, 1999.
Appellant raised one assignment of error to the Supreme Court, arguing that the RTC erred in not requiring the prosecution to prove his guilt despite his plea of guilty to a capital offense, invoking Section 3, Rule 116 of the Rules of Court. The Solicitor General filed a manifestation concurring with appellant and prayed for remand for presentation of evidence. The case reached the Court by automatic review of a death penalty conviction.
Issues:
- Did the trial court err in not requiring the prosecution to present evidence to prove appellant’s guilt and the precise degree of his culpability after he pleaded guilty to capital offenses in violation of Section 3, Rule 116?
- Did the trial court’s judgment violate Section 14, Article VIII of the 1987 Constitution by failing to clearly and distinctly express the facts and the law on which it was based?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)