Case Summary (G.R. No. 140713)
Procedural History
Two separate Informations were filed before the RTC for each incident. Documento initially pleaded not guilty, then changed his plea to guilty upon arraignment and re-arraignment. The prosecution presented testimonies from AAA, her mother BBB, and Dr. Hugo. Documento testified in his defense, claiming consensual relations and contesting venue, and disowned letters attributed to him.
RTC Decision
The RTC found Documento guilty beyond reasonable doubt of both counts of rape and sentenced him to death under Article 335, as amended by R.A. 7659. It awarded AAA ₱75,000 civil indemnity, ₱50,000 moral damages, and ₱25,000 exemplary damages per count, and ordered commitment to the Bureau of Corrections, Muntinlupa. The case was forwarded for mandatory Supreme Court review.
CA Ruling
On remand, the Court of Appeals affirmed guilt but modified the penalty to reclusion perpetua without parole in lieu of death, increased moral damages to ₱75,000 per count, and maintained civil indemnity and exemplary damages.
Issues on Appeal
- Whether the RTC had territorial jurisdiction over the offenses.
- Whether the plea of guilt was entered voluntarily and with full comprehension, in compliance with due process.
Analysis on Territorial Jurisdiction
Under Rule 129, Section 1, the court must take judicial notice of the geographic divisions of the Philippines. AAA’s sworn statement and the prosecutor’s resolution expressly located the acts in Barangay Antongalon and Ochoa Avenue, both within Butuan City. The Informations repeated those allegations. The CA correctly found that proof of venue was satisfied and that mandatory judicial notice confirmed Butuan City jurisdiction.
Analysis on Guilty Plea
Although the trial court failed to conduct the prescribed “searching inquiry” on voluntariness and full comprehension of the plea, the CA and Supreme Court held that the conviction rested not solely on the plea but on ample and credible evidence—victim’s consistent testimony, medical findings of healed laceration, family and police corroboration. Under People v. Mira, an improvident plea does not require remand if independent evidence supports guilt. Due process was vindicated by the evidence, and the plea’s improvidence did not
...continue readingCase Syllabus (G.R. No. 140713)
Procedural History
- Two separate Informations (Crim. Case Nos. 6899 and 6900) charged appellant Oscar M. Documento with two counts of rape under Article 335, Revised Penal Code, as amended by R.A. 7659.
- Appellant initially pleaded not guilty, then changed his plea to guilty upon re-arraignment.
- RTC Branch 5, Agusan del Norte and Butuan City (Judge Augustus L. Calo) rendered judgment on June 9, 2003.
- RTC convicted appellant beyond reasonable doubt of both counts, imposed death penalty for each count, awarded civil indemnity (P75,000), moral (P50,000), and exemplary (P25,000) damages per count, and committed appellant to the Bureau of Corrections.
- Appeal to the Court of Appeals (CA-G.R. CR-HC No. 00285) affirmed conviction on August 13, 2008, modified penalty to reclusion perpetua without possibility of parole, increased moral damages to P75,000 per count.
- Appeal to the Supreme Court (G.R. No. 188706) argued errors on territorial jurisdiction and propriety of the guilty plea inquiry; SC decision promulgated March 17, 2010.
Facts
- Victim AAA, daughter of appellant, first molested in 1989 at age 10; became pregnant and gave birth in 1993.
- Two charged incidents:
- October 15, 1995, at Barangay Antongalon, Butuan City.
- April 22, 1996, on Ochoa Avenue, Butuan City.
- Appellant used physical force, intimidation, and death threats to compel victim’s silence.
- Incidents occurred at residences of relative Barsilisa Morada and of Aida Documento in Butuan City.
Evidence Presented at Trial
- AAA’s testimony: detailed chronology of molestation since age 10, specific dates, places, use of force and threats.
- BBB’s (mother) testimony: absence from family 1994–1996, search efforts, report to Butuan police upon learning of AAA’s pregnancy.
- Dr. Johann A. Hugo’s medical examination: healed vaginal laceration, easy admission of two