G.R. No. 129299 ; November 15, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RODOLFO OLING MADRAGA, accused-appellant.

FACTS

Rodolfo Oling Madraga was charged with two counts of rape committed against his 16-year-old daughter, Fe C. Madraga. During arraignment, he initially pleaded not guilty. Subsequently, through counsel, he manifested a willingness to plead guilty to one count (Criminal Case No. 2511-599 for an incident in May 1995) on the condition that the other case be tried separately. The trial court accepted this plea of guilty. The prosecution then presented evidence, primarily Fe’s testimony detailing the rape and subsequent repeated abuses, corroborated by a medical certificate. Fe testified that her father, taking advantage of her mother’s absence abroad, sexually assaulted her starting May 1995 and repeatedly thereafter.
The Regional Trial Court found Madraga guilty beyond reasonable doubt of rape qualified by the victim being his daughter. The court imposed the death penalty, citing the mandate of the law for such a qualified offense. The case was elevated to the Supreme Court for automatic review due to the imposition of the capital penalty.

ISSUE

The primary issue is whether the trial court committed reversible error in accepting the accused-appellant’s plea of guilty and in imposing the death penalty.

RULING

The Supreme Court affirmed the conviction but modified the penalty. The Court held that the trial court committed a grave error in failing to conduct a “searching inquiry” as mandated by Section 3, Rule 116 of the Rules of Criminal Procedure when an accused pleads guilty to a capital offense. This inquiry is crucial to ensure the plea is made voluntarily and with full comprehension of its consequences. The trial court’s omission constituted a denial of due process, rendering the plea of guilty invalid.
Nonetheless, the conviction stands because the prosecution duly presented evidence to prove guilt beyond reasonable doubt independently of the invalid plea. Fe’s categorical and credible testimony, which was consistent and supported by medical findings, sufficiently established all elements of rape. The defense of intoxication raised by the appellant was correctly rejected, as voluntary drunkenness is not an exempting circumstance. However, the death penalty could not be sustained. The qualifying circumstance that the victim is a daughter of the accused must be alleged with specificity in the information. The complaint in this case failed to explicitly state Fe’s age (16 years) and her relationship to the accused as his daughter. This deficiency precludes the imposition of the death penalty. The proper penalty is reclusion perpetua. The Court also awarded civil indemnity and moral damages to the victim.