GR 168326; (April, 2007) (Digest)
G.R. No. 168326 ; April 11, 2007
PEOPLE OF THE PHILIPPINES, Petitioner, vs. PATRICIO PIOQUINTO, Respondent.
FACTS
The respondent, Patricio Pioquinto, was charged with two counts of qualified rape against his then 12-year-old daughter, AAA. The informations alleged that on October 18, 2000 and March 3, 2001, he, armed with a knife and through force and intimidation, had carnal knowledge of AAA against her will. After pleading not guilty, the respondent manifested during trial a desire to change his plea to guilty. The trial court required a written motion, but the respondent instead filed a motion for reduction of penalty, which was denied. Trial proceeded, with AAA testifying to the violent assaults, her subsequent pregnancy, and the birth of a child. Her mother and a medico-legal expert corroborated key details.
ISSUE
The core issue was whether the trial court erred in convicting the respondent of two counts of qualified rape and imposing the death penalty, despite his manifestations of a desire to plead guilty and the absence of a formal re-arraignment for such a changed plea.
RULING
The Supreme Court affirmed the conviction but modified the penalty. The legal logic centered on the proper procedure for a change of plea and the sufficiency of evidence. A plea of guilty must be entered voluntarily and with full comprehension of its consequences, necessitating a re-arraignment where the accused is formally informed of the charge and the plea is recorded. The respondent’s mere manifestations and his filing of a motion for penalty reduction did not constitute a valid plea of guilty; they were correctly treated as a mere offer of compromise, which is not admissible in criminal cases for rape. Consequently, the trial court rightly proceeded to trial.
On the merits, the prosecution evidence, particularly AAA’s credible and categorical testimony, which was consistent with medical findings and established her pregnancy, proved the respondent’s guilt beyond reasonable doubt for two counts of rape. The qualifying circumstances of minority and relationship were duly proven. However, pursuant to Republic Act No. 9346 , which prohibited the death penalty, the Court modified the penalty from death to reclusion perpetua without eligibility for parole for each count. The awards of civil indemnity, moral damages, and exemplary damages were affirmed.