Case Digest (G.R. No. 140208)
Facts:
People of the Philippines v. Elpidio Pastor, G.R. No. 140208, March 12, 2002, Supreme Court En Banc, Puno, J., writing for the Court. The plaintiff-appellee is the People of the Philippines; the accused-appellant is Elpidio Pastor (charged in the Information as the biological father of the victim).On March 12, 1999 an Information was filed charging Pastor with incestuous rape under Article 266-B of the Revised Penal Code as amended by R.A. No. 8353, alleging that on or about May 7, 1998 in Loon, Bohol he forcibly had carnal knowledge of his daughter, then aged 13, resulting in pregnancy. Pastor was arraigned on April 8, 1999 and initially pleaded not guilty; with assistance of a public attorney he changed his plea to guilty at a June 23, 1999 proceeding and was re-arraigned with the Information read and translated in Visayan.
At re-arraignment the trial court propounded a limited set of questions to Pastor (about identity, family background and whether he understood that a plea might expose him to the death penalty). Pastor testified in support of mitigating circumstances (plea of guilty, voluntary surrender, and non-habitual drunkenness). The prosecution thereafter presented complainant Maria Nina R. Pastor, who testified that her father raped her on May 7, 1998 at about 3:00 a.m.; she said she became pregnant and delivered on December 12, 1998 (the infant died five days later). The prosecution offered documentary evidence: complainant’s birth certificate and two medical certificates relating to pregnancy and delivery. Defense counsel did not cross‑examine the complainant and expressed conformity to admission of the prosecution’s documents.
On August 30, 1999 the Regional Trial Court, Branch 2, Tagbilaran City (Judge Baudilio K. Dosdos) found Pastor guilty beyond reason...(Subscriber-Only)
Issues:
- Did the trial court comply with Section 3, Rule 116 of the 1985 Rules of Criminal Procedure by conducting a searching inquiry into the voluntariness of the guilty plea and the accused’s comprehension of its consequences?
- Did the prosecution present evidence, independent of the guilty plea, sufficient to prove the accused’s guilt and the precise degree of his culpability beyond reasonable doubt?
- Was the performance of defense counsel adequate to protect the accused’s const...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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