G.R. No. 132524 - Suntay vs. Cojuangco-Suntay

Endrico Galas, the accused-appellant, was charged with three counts of rape committed against his daughter, Sharon Galas.
The charges arose from three separate incidents allegedly occurring on:

All incidents took place in Sibunag, Province of Guimaras, Philippines, within the court’s jurisdiction.

The criminal case records (Criminal Case Nos. 0333, 0334, and 0335) detail each rape allegation, with the charge specifying that Galas administered the offense by means of force and intimidation.
The complaint was primarily filed by Sharon Galas, identified as a 15-year-old daughter (although testimony later suggests she was 17 at the time of trial testimony).
The charges focused on non-consensual carnal knowledge, with explicit elements of intimidation and the special familial relationship intensifying the severity of the offense.

At arraignment on April 28, 1998, the accused pleaded not guilty in all three cases.
On May 7, 1999, and reiterated on June 3, 1999, the accused expressed his desire through counsel to change his plea from not guilty to guilty only in Criminal Case No. 0334 (the incident on February 28, 1997).
Upon re-arraignment, the accused, represented by counsel, entered a plea of guilty in Criminal Case No. 0334.
The prosecution presented Sharon Galas as the primary witness:

She recounted in detail the rape incident that occurred on February 28, 1997, as well as events from February 5, 1997, and an unclear time in July 1997.
Her testimony included explicit details such as instructions given by her father, the setting in her grandmother’s house, and the use of force (notably mentioning the possession of a bolo).

A medical examination conducted on August 7, 1997, by a rural health physician documented loss of virginity and healed hymenal lacerations, which served as corroborative evidence of the abuse.

He argued that he was not fully informed of the ramifications, particularly that a plea of guilty in this context could lead to the imposition of the death penalty.

Confirmed that he was informed he could face reclusion perpetua or death.
However, it was later argued that he had not been adequately apprised that death was the mandatory penalty in the presence of aggravating circumstances.

Failing to ascertain whether the accused was offered the opportunity to present evidence in his favor.
Not fully exploring the accused’s understanding regarding the condemnation implications of his plea.

Article 63 of the Revised Penal Code and Section 11 of R.A. No. 7659 require indubitable evidence of the victim’s age for the imposition of the death penalty.
The prosecution’s evidence regarding Sharon Galas’s age was primarily based on her testimony:

Her statement that she was 17 years old at the time she testified was found insufficient as conclusive evidence.

No corroborative evidence (e.g., a certified birth certificate, baptismal certificate, or school record) was properly introduced during trial to authenticate her actual age.
Consequently, the prosecution’s failure to produce such documentary evidence rendered the imposition of the death penalty legally unsustainable.

On conviction in Criminal Case No. 0334, the trial court originally imposed a death penalty on the accused-appellant, finding him guilty beyond reasonable doubt.
Criminal Cases Nos. 0333 and 0335 were dismissed.
On automatic review, while the evidence was deemed sufficient to establish guilt, critical procedural errors regarding the plea were identified.
The decision was modified:

The improvident change of plea was set aside.
The imposition of the death penalty was vacated due to insufficient evidence regarding the victim's age.
The accused-appellant was ultimately convicted of simple rape and sentenced to reclusion perpetua.
The court modified the award of damages to:

Whether the accused-appellant’s plea of guilty in Criminal Case No. 0334 was made voluntarily and with full comprehension of its consequences, particularly regarding the imposition of the death penalty.
Whether the procedural safeguards required to prevent an improvident plea were properly observed by the trial court, specifically the inquiry into the accused’s understanding of the possible penalties.
Whether the prosecution met the necessary burden of proving beyond reasonable doubt all elements of the offense, including the victim’s age, as required under the law for the imposition of death as a penalty.
Whether the failure of the trial court to ensure that the accused had an opportunity to present evidence on his behalf amounted to reversible error.