GR 124300; (March, 1999) (Digest)
G.R. No. 124300 March 25, 1999
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RENANTE ROBLES y BURGOS, JR., Alias “TITING”, accused-appellant.
FACTS
Accused-appellant Renante Robles Jr. was charged with the rape with homicide of five-year-old Gerafil Cabatingan. After initially pleading guilty without counsel, he was re-arraigned with the assistance of a Public Attorney’s Office lawyer and entered a plea of not guilty. He later changed his plea to guilty, which the trial court accepted after a searching inquiry confirmed his voluntary and intelligent understanding of the plea’s consequences, including the imposable death penalty. The prosecution presented evidence establishing that on August 29, 1995, Robles lured the victim away from her siblings, brought her to a barangay health center, and was later seen emerging from it, bloodied. The victim was found inside, severely beaten, sexually assaulted, and unconscious; she died later that day. Medical findings confirmed contusions, lacerations, and evidence of recent sexual intercourse.
ISSUE
The core issue is whether the trial court correctly imposed the death penalty based on the accused’s plea of guilty and the evidence presented, and whether the awards for damages were proper.
RULING
The Supreme Court affirmed the conviction and the imposition of the death penalty. The Court held that the trial court meticulously complied with the procedural requirements for a plea of guilty to a capital offense. The searching inquiry was sufficient, and the plea was made with full assistance of competent counsel. This judicial confession, coupled with the overwhelming corroborative evidence—including eyewitness accounts placing the accused with the victim and the damning medico-legal findings—conclusively established his guilt beyond reasonable doubt. The crime qualified under Article 335 of the Revised Penal Code, as amended by Republic Act No. 7659 , for rape with homicide, warranting the supreme penalty. On damages, the Court affirmed the award of P100,000.00 as civil indemnity and P50,000.00 as moral damages, the latter being recoverable without need of detailed proof given the evident trauma. However, the award of P60,000.00 as actual damages was deleted for lack of supporting receipts. The records were ordered forwarded to the Office of the President pursuant to law.