Case Digest (G.R. No. 179187)
Facts:
The case involves Renato Talusan y Panganiban (appellant) who was convicted of kidnapping with rape of a six-year-old minor, referred to as AAA. The events transpired between January 15 and January 23, 2004, in Las Piñas City, Philippines. The Information filed against the appellant indicated that he, in conspiracy with an unidentified individual named Eljoy Salonga, unlawfully kidnapped AAA and subjected her to sexual abuse over a period of eight days. On January 14, 2004, while AAA was on her way to school, the appellant lured her 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 taking her to Jollibee, he brought 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 by inserting his finger into her vagina.
AAA's stepfather, BBB, reported her missing after she fail...
Case Digest (G.R. No. 179187)
Facts:
Incident Overview:
- On January 14, 2004, AAA, a six-year-old minor, was kidnapped by appellant Renato Talusan y Panganiban while on her way to school in Las Piñas City.
- Appellant lured AAA by promising to take her to Jollibee, a place she was familiar with, as they both attended Sunday Bible classes.
- Instead, appellant took AAA to a house in Imus, Cavite, where she was detained for eight days.
Abuse During Detention:
- During her detention, appellant sexually abused AAA by inserting his finger into her vagina daily, despite her resistance.
- AAA’s stepfather, BBB, reported her disappearance to the police after she failed to return home.
Apprehension and Medical Examination:
- Appellant and AAA were apprehended on January 23, 2004.
- A medico-legal examination revealed deep fresh lacerations in AAA’s hymen, consistent with recent loss of virginity.
Legal Proceedings:
- Appellant was charged with kidnapping with rape under Article 267 of the Revised Penal Code, as amended by Republic Act No. 7659.
- During arraignment, appellant pleaded guilty, and the trial court conducted a searching inquiry to ensure the voluntariness of his plea.
- Despite his plea, the trial court ordered the prosecution to present evidence, which included AAA’s testimony and the medico-legal report.
Trial Court Decision:
- The trial court convicted appellant of kidnapping with rape and sentenced him to death.
- The case was automatically reviewed by the Supreme Court due to the imposition of the death penalty.
Appellate Court Decision:
- The Court of Appeals affirmed the conviction but modified the penalty to reclusion perpetua without eligibility for parole, in accordance with Republic Act No. 9346, which prohibits the death penalty.
Issue:
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Ruling:
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Ratio:
Voluntariness of Guilty Plea:
- A searching inquiry is required to ensure that a guilty plea is made voluntarily and with full understanding of its consequences. The trial court’s thorough questioning of appellant satisfied this requirement.
Proof of Kidnapping with Rape:
- The special complex crime of kidnapping with rape requires proof of both kidnapping and rape. AAA’s credible testimony and the medico-legal findings established these elements beyond reasonable doubt.
Penalty Modification:
- Republic Act No. 9346 prohibits the imposition of the death penalty, necessitating the modification of appellant’s sentence to reclusion perpetua without parole.
Award of Damages:
- Civil indemnity and moral damages are mandatory in rape cases. The amounts were increased to P75,000 each to align with current jurisprudence.