G.R. No. 130203 -04 February 15, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ABUNDIO MANGILA y PAREÑO, accused-appellant.

FACTS

Accused-appellant Abundio Mangila was charged with two counts of rape against his 16-year-old daughter, Madrilyn. The informations alleged that on June 7 and 9, 1995, in Teresa, Rizal, he had forcible sexual intercourse with her. Upon arraignment, while admitting guilt, he invoked the alternative circumstance of intoxication. The trial court entered a plea of not guilty and proceeded to trial.
The prosecution established that on both dates, the accused brought Madrilyn to a house he was caretaking under the pretext of cleaning. There, he forcibly removed her clothing, poked a knife at her neck, and raped her despite her pleas. The victim’s silence was broken days later, leading to a confrontation where the accused admitted his acts to his wife and begged for forgiveness. A medical examination confirmed Madrilyn’s non-virginal state. The defense solely relied on the accused’s testimony, where he admitted the rapes but claimed he was intoxicated on both occasions due to marital problems.

ISSUE

Whether the trial court erred in convicting the accused and imposing the death penalty despite his claim of a defective arraignment and the mitigating circumstance of intoxication.

RULING

The Supreme Court affirmed the conviction but modified the award of damages. The claim of a defective arraignment was unmeritorious. The accused’s initial admission of guilt was correctly disregarded by the trial court, which instead entered a not guilty plea and conducted a full trial. This procedure cured any potential defect, and the conviction was based on the overwhelming evidence adduced during trial, not on a plea.
The Court rejected the claim of intoxication as a mitigating circumstance. For voluntary intoxication to mitigate criminal liability, it must be proven that the accused was so inebriated as to completely deprive him of reason or discernment at the time of the crime. The accused’s own testimony revealed a clear recollection of the events, including the victim’s pleas and his deliberate actions of using a knife and forcing intercourse. This demonstrated not a loss of reason but a purposeful execution of the crime. The qualifying circumstance of relationship (father-daughter) and the victim’s minority were duly proven, mandating the imposition of the death penalty for each count of incestuous rape under Article 335 of the Revised Penal Code, as amended by R.A. 7659. The Court affirmed the penalty but increased the civil indemnity and awarded moral and exemplary damages in line with prevailing jurisprudence.