Facts:

In the case of People of the Philippines vs. Gregorio Lima y Silpa, G.R. No. 128289, decided on April 23, 2002, the accused, Gregorio S. Lima, faced charges of incestuous rape filed by his own daughter, Sherilyn Lima, in the Regional Trial Court (RTC), Branch 17, Davao City. The charges were detailed in two separate criminal cases: Criminal Case No. 36,517-96 and Criminal Case No. 36,380-96. In the first case, Sherilyn, then a minor, accused her father of raping her at age 10 in 1992 under threat that he would harm their family if she spoke about it. The second charge stemmed from an incident on January 20, 1996, when Sherilyn, now 14, was again assaulted by her father while her mother was away at a birthday party. In court, Sherilyn testified about the traumatic experiences she endured, detailing each incident of rape and asserting her pleas for him to stop went unheard. The mother, Erlinda Lima, confirmed these events, describing her shock upon returning home and finding her d

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Facts:

Consolidation and Nature of the Cases

• Two separate criminal cases involving the same accused, Gregorio S. Lima, were consolidated in RTC Branch 17, Davao City.
• Criminal Case No. 36,517-96 and Criminal Case No. 36,380-96 both charged the accused with rape, with the victim being his daughter, Sherilyn Lima.
• The charges pertain to incestuous rape, a heinous crime that evokes profound public outrage and repulsion.

The Offenses Charged

• In Criminal Case No. 36,517-96:
• The accused was charged with raping his daughter when she was below 14 years of age, in 1992, within the City of Davao.
• The charge alleged that by means of force, intimidation, and abuse of superior strength, the accused deprived the minor of her will and dignity.
• In Criminal Case No. 36,380-96:
• The accused was again charged with rape, this time with the victim being 14 years old on January 20, 1996.
• The information specified that the rape was committed while the victim was asleep in the sala, and the accused used threats of harm to prevent her from resisting.

Evidence and Testimonies Presented

• Victim’s Testimony
• Sherilyn Lima testified extensively about the repeated sexual assaults by her father, beginning when she was 10 years old in 1992.
• She described in detail the events of January 20, 1996, including being roused from sleep, taken to the master’s bedroom, forced to undress, and raped.
• Her consistent and emotionally charged account was supported with documentary evidence such as her Certificate of Live Birth.
• Testimony of Other Witnesses
• Erlinda Lima (the victim’s mother) testified on discovering her daughter’s state after the incident, her subsequent actions at the police station, and details of her daughter’s condition.
• SPO2 Ricardo M. Arcilla corroborated the sequence of events by detailing his role in arresting the accused.
• Dr. Danilo P. Ledesma, the medico-legal officer, provided reports from the medical examination, noting healed deep lacerations on the victim’s hymen and the presence of spermatozoa.
• Accused’s Admission and Plea
• The accused initially pleaded not guilty in separate arraignments but eventually changed his plea to guilty during rearraignment proceedings.
• In his testimony, he admitted to raping his daughter on both occasions and offered an explanation—attributing the acts to a loss of composure when he was drunk.

Trial Court Proceedings and Judgment

• The trial court accepted the guilty plea but expressly required that the evidence of the prosecution be presented to prove the crimes beyond reasonable doubt.
• The court rendered a Joint Judgment:
• In Criminal Case No. 36,517-96, the accused was sentenced to reclusion perpetua.
• In Criminal Case No. 36,380-96, a sentence of death by electrocution was imposed.
• The judgment also provided for civil indemnity, ordering the accused to pay damages in the form of moral, indemnity ex delicto, and exemplary damages to the victim, with adjustments made upon appeal.

Appellant’s Argument on Appeal

• The sole assignment of error was that the trial court improvidently accepted the plea of guilty without observing the mandatory provisions of Sec. 3, Rule 116 of the Revised Rules of Criminal Procedure.
• The accused contended that the court failed to prove that he fully comprehended the separate charges and the grave consequences—especially the imposition of the death penalty in one of the cases.
• The appellant argued that his plea was fatally defective because he was not adequately warned or informed of all of its legal implications.

Judicial Findings on the Plea and the Evidence

• The trial court and subsequently the appellate court found that the accused’s plea of guilty was voluntary and accompanied by a clear explanation of its consequences.
• Despite the appellant’s arguments regarding the improvidence of his plea, substantial corroborative evidence—from the victim’s consistent account to the testimonies of other eyewitnesses and medical findings—substantiated the conviction.
• The credibility of the witnesses and the extensive cross-examination lent significant weight to the finding of guilt, independent of the plea itself.

Issue:

• Whether the trial court erred in accepting the accused’s plea of guilty without a more rigorous inquiry into his understanding and voluntariness as required under Sec. 3, Rule 116 of the Revised Rules of Criminal Procedure.
• Whether the conviction was based solely on the plea of guilty or was sufficiently supported by the body of evidence provided by the prosecution.
• Whether the trial court correctly imposed reclusion perpetua in one case and the death penalty in the other given the evidence of the heinous acts committed.
• Whether the award of damages to the victim, initially set at P30,000.00 for moral damages, should be modified in light of prevailing jurisprudence and the aggravating circumstance of incest.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)