Title
People vs. Talusan y Panganiban
Case
G.R. No. 179187
Decision Date
Jul 14, 2009
Renato was convicted of raping a minor and sentenced to reclusion perpetua, with increased civil indemnity and moral damages, based on the victim's credible testimony and supporting medical evidence.
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Case Digest (G.R. No. 179187)

Facts:

  • Renato Talusan y Panganiban (appellant) was convicted of kidnapping with rape of a six-year-old minor, referred to as AAA.
  • The events occurred between January 15 and January 23, 2004, in Las Piñas City, Philippines.
  • The Information indicated that the appellant conspired with an unidentified individual, Eljoy Salonga, to unlawfully kidnap AAA and sexually abuse her over eight days.
  • On January 14, 2004, the appellant lured AAA by promising to take her to Jollibee, a popular fast-food chain.
  • Trusting him as a fellow attendee of Sunday Bible classes, AAA accompanied him instead of going to Jollibee.
  • The appellant took her to a house in Imus, Cavite, where he introduced her as his daughter.
  • During the eight days of captivity, the appellant repeatedly sexually abused AAA.
  • AAA's stepfather, BBB, reported her missing after she did not return home.
  • BBB located the appellant and AAA on January 23, 2004, leading to the appellant's arrest.
  • A medico-legal examination revealed injuries consistent with recent sexual abuse.
  • The Regional Trial Court (RTC) found the appellant guilty based on his voluntary plea and evidence, sentencing him to death.
  • The Court of Appeals modified the sentence to reclusion perpetua without eligibility for parole, affirming the conviction but adjusting the penalties.

Issue:

  • (Unlock)

Ruling:

  • The Court ruled that the appellant's plea of guilty was not improvident, as the trial court conducted a proper searching inquiry.
  • The evidence presented was sufficient to support the conviction of kidnapping with rape, establishing the elements of the crime beyond reasonable doubt.
  • The penalty of death was modified to rec...(Unlock)

Ratio:

  • The Supreme Court emphasized the necessity of a searching inquiry to ensure a plea of guilty is made voluntarily and with full understanding of its consequences.
  • The trial court conducted a thorough inquiry into the appellant's understanding of the charges and the implications of his plea, confirming he was not coerced or...continue reading

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