Case Summary (G.R. No. L-60073)
Plea of Guilty and Testimony of the Victim
- The appellants, Nenito C. Ferrer, Rodolfo Zulueta, and Nelson Maico, pleaded guilty to the charge of robbery with multiple rape during their arraignment.
- The trial court ensured that the appellants were fully aware of the consequences of their guilty plea.
- The victim, Lena Estrella, a minor, provided testimony detailing the sexual abuse inflicted upon her by the appellants.
- Lena's testimony was deemed credible, as she had no ulterior motive for her accusations and would not falsely claim dishonor.
- Medical evidence corroborated Lena's testimony, with Dr. Ruperta Caluag confirming fresh lacerations consistent with sexual assault.
Aggravating Circumstances and Penalty
- The crime of robbery with rape carries a penalty of reclusion perpetua to death under the Revised Penal Code.
- The trial court identified several aggravating circumstances:
- The crime was committed at night.
- The use of a motor vehicle facilitated the escape of the perpetrators.
- The victims were hogtied and gagged, which weakened their ability to defend themselves.
- Due to these aggravating factors, the trial court initially imposed the death penalty.
- However, the death penalty was commuted to reclusion perpetua due to a lack of necessary votes among the justices.
Facts of the Case
- The incident occurred around midnight on August 15, 1979, when the appellants forcibly entered the home of Teresa Estrella in Guiguinto, Bulacan.
- Armed with a firearm and a knife, they threatened the family and demanded money and jewelry.
- The appellants successfully stole valuables worth over P176,250.00 and sexually assaulted Lena Estrella.
- The crime was reported to the police shortly after the incident, leading to an investigation that corroborated the victims' accounts.
Trial Court's Findings
- The trial court found overwhelming evidence of robbery and multiple rapes committed by the appellants.
- The court noted that the appellants acted in concert, using deadly weapons to intimidate the victims.
- The court emphasized that the pleas of guilty did not mitigate the severity of the crime due to the presence of aggravating circumstances.
Appellants' Defense and Court's Response
- The appellants contended that while they admitted to robbery, they denied the charges of rape.
- The court rejected this defense, affirming that the guilty pleas and the evidence presented were sufficient to uphold the convictions.
- The court r...continue reading