G.R. No. 137256-58 - People vs. Ernas

Appellant Rufino Ernas y Villanueva was charged in three separate criminal cases (Crim. Case Nos. 6178-98-C, 6179-98-C, and 6180-98-C) for the crime of rape.
The charges pertained to acts committed against his daughters:

In Criminal Case No. 6178-98-C, he was accused of raping his 14-year-old daughter AAA on or about May 11, 1998.
In Criminal Case Nos. 6179-98-C and 6180-98-C, he was accused of raping his 15-year-old daughter BBB on or about September 21, 1998, and September 18, 1998, respectively.

Each charge alleged that the rape was committed with lewd design, by force and intimidation, and against the will and consent of the victims.

On October 27, 1998, three separate Informations were filed with the trial court detailing the specific acts and circumstances of the crimes.
During the pre-trial conference held on December 9, 1998, the court noted several stipulated facts including:

At the initial hearing on January 13, 1999, and with the assistance of counsel, the appellant entered a plea of not guilty.
Subsequently, at a later hearing:

The appellant decided to withdraw his plea of not guilty and entered a plea of guilty after reaffirming that his decision was voluntary and made with a full understanding of its consequences.
The trial court, after re-arraigning him and reading the Informations again in a language he understood (Tagalog), accepted his voluntary plea of guilty to all three counts of rape.

The prosecution, relying on the plea and certain documentary exhibits (complaints, sworn statements, and Medico-Legal Certificates), dispensed with the direct testimony of the complaining witnesses.
The trial court rendered a joint judgment on January 14, 1999, convicting the appellant on all counts and sentencing him to the penalty of death for each charge, with additional monetary indemnification for moral damages.
The dispositive portion of the decision stated that the plea of guilty was voluntary and that cost penalties were imposed against the accused.

The appellant raised the issue that, despite his plea of guilty, the trial court erred in not requiring the prosecution to prove his guilt and the precise degree of his culpability.
His argument was based on Section 3 of Rule 116 of the 1985 Rules of Criminal Procedure, which mandates:

A thorough inquiry into the voluntariness and understanding of the consequences of the plea.
The requirement that the prosecution introduce evidence to independently prove the guilt and degree of culpability in capital cases.

The failure of the trial court to confirm whether the appellant was fully apprised of the consequences of his plea.
The absence of investigation into matters such as the accuracy of the victims’ ages and other factual discrepancies that would affect the proper qualification of the crimes.
The lack of a complete narrative recounting his acts which is critical to verifying the appellant’s informed and competent waiver of his rights.

The decision cites guidelines from People vs. Pastor and other cases that outline the mandatory inquiries for a plea of guilty in capital offenses.
These guidelines require detailed interviewing of the accused regarding:

The circumstances under which he was taken into custody.
Whether competent counsel was present during interrogations.
The accused’s socio-economic status, age, and educational background to determine his capacity to understand the implications of the plea.

It emphasizes that the failure to properly question the accused or require the introduction of evidence constitutes a grave abuse of judicial discretion, especially where the death penalty is at risk.

Whether the trial court erred in not requiring the prosecution to present evidence to independently prove the guilt of the accused and to determine the precise degree of his culpability, notwithstanding his plea of guilty to a capital offense.

The issue centers on the application of Section 3 of Rule 116 of the 1985 Rules of Criminal Procedure.
The appellant contended that despite his plea, the full evidentiary requirement prescribed by law was not met.

Whether the trial court fulfilled its duty to conduct a "searching inquiry" into the voluntariness and full understanding of the consequences of the accused’s plea.

Determining if the appellant was properly informed and capable of making an informed plea.
Assessing if the trial court adequately examined the circumstances surrounding his decision to change his plea.

Whether the trial court erred in waiving the presentation of direct testimony and other evidence which could clarify significant factual discrepancies, particularly regarding the age of the victims.

The proper qualification of the crimes of rape and the subsequent imposition of the death penalty depend on these details.
Failure to require further proof could undermine the integrity of the sentencing.

Whether the trial court’s decision met the constitutional requirement of clearly stating the facts and law supporting its judgment, as mandated by Section 14, Article VIII of the Constitution.