Case Summary (G.R. No. 147965)
Factual Background
On October 20, 2000, in the municipality of Sikatuna, Bohol, Rey Apatay y Balo was accused of committing rape with homicide against 77-year-old Catalina Baluran. The information filed against him detailed the brutal circumstances of the crime, asserting that Apatay, motivated by lewd design and using force, entered the victim's house, assaulted her, and ultimately killed her to prevent her from identifying him.
Proceedings and Trial Court Analysis
During arraignment with the assistance of Atty. Adriano P. Damalerio from the Public Attorney's Office, Apatay entered a plea of guilty. The trial court conducted a searching inquiry to ascertain the voluntariness of his plea and whether he understood its implications. Witnesses, including neighbors and a medical expert, provided testimony that corroborated the prosecution's case, detailing the victim's injuries and cause of death, which was determined to be a massive hemorrhage resulting from skull fractures.
Admission and Confession
After the crime, on October 24, 2000, Apatay surrendered to the police, confessing to the crime in a sworn statement, where he admitted to the rape and subsequent killing of Baluran. The confession contained explicit details of the event that only someone privy to the incident could provide, reinforcing the credibility of the evidence against him.
Court's Decision
On March 5, 2001, the trial court found Apatay guilty beyond a reasonable doubt of rape with homicide, imposing the death penalty and ordering him to indemnify the victim’s heirs P100,000.00. The court's decision followed Articles 266-A and 266-B of the Revised Penal Code, which stipulate severe penalties for such crimes.
Arguments on Appeal
In his appeal, Apatay contended that the trial court did not sufficiently inquire into his understanding of the plea or provide him with the opportunity to present evidence in his defense. The Solicitor General, representing the People, defended the trial court’s procedures, arguing that all necessary protocols were adhered to in the arraignment, including the proper advisement of Apatay’s rights.
Legal Standards for Pleas in Capital Cases
The applicable procedural rules outlined that a thorough inquiry must precede a guilty plea in capital offenses, ensuring the accused is fully informed and understands the consequences. The court emphasized that the plea must be voluntary and based on genuine guilt, with judges exercising their discretion in accordance with the guidelines established in prior jurisprudence.
Affirmation of Lower Court's Decision
The Supreme Court affirmed the lower court’s decision, highlighting adherence to the necessary judicial processes and the substantial evidence indicating Apatay’s guilt. It upheld the imposition of the
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Case Overview
- The case pertains to the conviction of Rey Apatay y Balo for the crime of Rape with Homicide.
- The Regional Trial Court, Branch 2, Tagbilaran City, sentenced the appellant to death and ordered him to indemnify the heirs of the victim, Catalina Baluran, in the amount of P 100,000.00.
- The decision, dated March 5, 2001, was subjected to automatic review by the Supreme Court.
Facts of the Case
- On October 20, 2000, Rey Apatay forcibly entered the home of 77-year-old Catalina Baluran while she was alone, where he committed sexual assault against her.
- After recognizing him, Catalina was attacked and killed by Apatay to prevent her from identifying him.
- Appellant used a piece of firewood to strike her, resulting in multiple injuries that caused her death, later confirmed by a post-mortem examination.
- The body of Catalina was discovered in an abandoned toilet on October 22, 2000.
Procedural History
- During arraignment, the appellant, assisted by Atty. Adriano P. Damalerio from the Public Attorney’s Office, pled guilty upon being read the Information in his native Visayan dialect.
- The trial judge conducted a search inquiry to ensure the plea was voluntary and informed, after which evidence was presented by the prosecution.
Prosecution Evidence
- Witnesses including Francisca Buchan and Odelion Manco testified that they saw Apatay near the victim's house on the night of the incident and confirmed the victim's absence the following morning.
- Dr. Francisco Romulo D. Villaflor conducted an autopsy,