GR 128289; (April, 2002) (Digest)
G.R. No. 128289 ; April 23, 2002
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. GREGORIO LIMA y SILPA, accused-appellant.
FACTS
Accused-appellant Gregorio Lima was charged with two counts of rape by his daughter, Sherilyn Lima. The first information alleged rape committed in 1992 when Sherilyn was ten years old. The second information detailed a specific incident on January 20, 1996, when she was fourteen. Initially pleading not guilty, Lima later changed his plea to guilty for both charges during rearraignment. The prosecution presented evidence, including Sherilyn’s testimony detailing the repeated sexual assaults by her father, which began when she was a child and continued for years under threats of violence. Her mother, Erlinda Lima, testified to discovering the 1996 incident and reporting it. Medical examination confirmed old hymenal lacerations and the presence of spermatozoa.
ISSUE
The core issue is whether the trial court correctly imposed the death penalty upon the accused-appellant’s plea of guilty, considering the nature of the crimes and the evidence presented.
RULING
The Supreme Court affirmed the conviction and the imposition of the death penalty for the qualified rape committed on January 20, 1996, and reclusion perpetua for the 1992 rape. The legal logic is anchored on the judicial duty to ensure a plea of guilty is entered intelligently and voluntarily, and that the conviction is supported by sufficient evidence. The Court meticulously examined the records, finding that the trial court conducted a proper searching inquiry into the voluntariness and comprehension of Lima’s guilty plea. Furthermore, the prosecution’s evidence—the credible and categorical testimony of the victim, corroborated by her mother’s account and the medico-legal findings—proved the crimes beyond reasonable doubt. For the 1996 rape, the qualifying circumstance of the victim being under eighteen and the offender being the parent was duly alleged and proven, warranting the death penalty under Republic Act No. 7659 . The Court modified the awards for damages, ordering indemnity, moral damages, and exemplary damages in accordance with prevailing jurisprudence. The decision was subject to automatic review for the imposition of the death penalty.