Case Digest (G.R. No. 133984)
Facts:
People of the Philippines v. Medrillo Rodriguez, G.R. No. 133984, January 30, 2002, Supreme Court En Banc, Vitug, J., writing for the Court.The accused-appellant, Medrillo Rodriguez, lived in a small shanty with his three motherless children. His eldest daughter, referred to in the record as AAA, cared for her younger siblings. In or about the second week of December 1995 and for some time thereafter, AAA complained that her father had carnal knowledge of her on multiple occasions and that she later gave birth to a son, BBB (also called Michael Rodriguez). AAA filed a complaint amended on January 24, 1997, charging Rodriguez with rape under Article 335 of the Revised Penal Code in relation to Republic Act No. 7610 (as alleged in the information).
At arraignment on October 15, 1997, the accused initially pleaded not guilty but later, through counsel, withdrew that plea and entered a plea of guilty. On January 14, 1998, the Regional Trial Court (RTC) (Branch 21, Kapatagan, Lanao del Norte) issued an order finding the accused guilty beyond reasonable doubt of multiple rape and sentenced him to reclusion perpetua and ordered indemnity of P50,000. Thereafter the RTC set aside that decision and directed the prosecution to prove the accused’s guilt and the precise degree of culpability. Following trial, the RTC rendered a decision dated April 22, 1998, convicting Rodriguez of rape as qualified under Art. 335 as amended by R.A. No. 7659 and sentenced him to death; the case was then forwarded to the Supreme Court for automatic review.
On appeal to the Supreme Court (automatic review because the trial court imposed the death penalty), the accused urged that the RTC did not comply with the mandatory "searching inquiry" required by Section 3, Rule 116 of the 1985 Rules on Criminal Procedure when it accepted his plea of guilty to a capital offense and that the colloquy showed he did not fully comprehend the consequences of the plea. The trial transcript showed an exchange in which the accused at times said he did not understand parts of the complaint, said “there is nothing I can do,” and counsel manifested that the accused “is willing to suffer imprisonment of 20 years” and asked the court to re-arraign and withdraw the former plea. The RTC record also contains testimonial evidence: AAA testified in detail about the assaults, her age at the time (stated as 15 for the December 1995 incident, the complaint alleged 16), that ...(Subscriber-Only)
Issues:
- Did the trial court substantially comply with Section 3, Rule 116 of the 1985 Rules on Criminal Procedure when it accepted the accused’s plea of guilty to a capital offense?
- If the plea was improperly taken, can the conviction nevertheless stand on independent evidence?
- Was the offense proved as qualified rape punishable by death under Article 335 as amended by R.A. No. 7659 (i.e., was the victim’s minority and the qualifying relationship sufficiently established)? ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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