Case Digest (G.R. No. 124300)
Facts:
People of the Philippines v. Renante Robles y Burgos, Jr., G.R. No. 124300, March 25, 1999, the Supreme Court En Banc, Per Curiam. The prosecution (People) appealed to the Supreme Court under the Court's automatic review of death sentences after the Regional Trial Court in Butuan City convicted Renante Robles y Burgos Jr. (alias "Titing") of rape with homicide and sentenced him to death.Robles was charged by information with having raped and, by reason or on the occasion of the rape, killed five-year-old Gerafil “Gigi” Cabatingan on August 29, 1995. At arraignment Robles initially pleaded guilty but the plea was disregarded because he had no counsel; the court appointed a Public Attorney and Robles then pleaded not guilty. His counsel later sought withdrawal of the not-guilty plea and Robles—after the trial court personally inquired, reading the information in Cebuano and confirming voluntariness—entered a plea of guilty.
At trial the prosecution presented five witnesses (the victim’s half-brother Randy, neighbor Sheila Yanez, Dr. Julie D. Lagare, playmate Luzviminda Villaro, and the victim’s father Edgar Cabatingan) and seven documentary exhibits including sworn statements, medical certificates, and the victim’s birth certificate. Testimony established that Robles was seen with the victim prior to their going to the barangay health center; Randy saw Robles leave the health center appearing bloodied and wiping something; voices and moaning were heard coming from the center; the victim was found bloody, unconscious, without underwear, with multiple head and body injuries and genital lacerations, positive for spermatozoa, and subsequently died of cardiopulmonary arrest the same day. Robles did not present evidence.
The trial court found Robles guilty beyond reasonable doubt of rape with homicide, sentenced him to death, and ordered payment of P60,000 actual damages, P50,000 moral damages, and P50,000 death indemnity; it also forwarded the record to the Supreme Court for automatic review. Robles' sole ...(Pro-only)
Issues:
- Was the conviction of Renante Robles properly supported where the prosecution relied largely on circumstantial evidence and the accused’s guilty plea?
- Was the imposition of the death penalty proper under Article 335 of the Revised Penal Code as amended by Section 11, Republic Act No. 7659?
- Were the civil awards (actual damages, moral damages, civil indemnity) properly granted and in the a...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)