GR 131814; (March, 2000) (Digest)
G.R. No. 131814 ; March 15, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RODOLFO ARIZAPA, accused-appellant.
FACTS
The accused-appellant, Rodolfo Arizapa, was charged with the incestuous rape of his 12-year-old stepdaughter, Rosita Encinas, on June 4, 1995, in Labo, Camarines Norte. The prosecution established that Rosita was sleeping when Arizapa entered her room, threatened her, and proceeded to have carnal knowledge of her. The medical examination confirmed hymenal lacerations. During the trial, after the prosecution had rested its case, Arizapa took the stand and, against his counsel’s advice, voluntarily admitted to committing the rape as charged.
ISSUE
Whether the trial court committed a reversible error by convicting the accused based on his improvident plea of guilt without conducting the mandatory searching inquiry required for capital offenses.
RULING
The Supreme Court affirmed the conviction and the imposition of the death penalty. While the trial court indeed failed to conduct the requisite “searching inquiry” into the voluntariness and full comprehension of Arizapa’s judicial admission of guilt, as mandated by Section 3, Rule 116 of the 1985 Rules on Criminal Procedure, this procedural lapse did not warrant an acquittal or a new trial. The rationale for the rule is to prevent improvident pleas in capital cases. However, the Court ruled that the error was rendered harmless because Arizapa’s admission was made only after the prosecution had already completed presenting its evidence. The prosecution’s evidence, meticulously scrutinized by the Court, was more than sufficient to prove guilt beyond reasonable doubt. The credible, straightforward, and corroborated testimony of the victim, alongside the medical findings, constituted proof of the corpus delicti independent of the accused’s admission. The crime was qualified as incestuous rape under Article 335 of the Revised Penal Code in relation to Republic Act No. 7659 , due to the victim’s minority and her relationship to the offender as a stepchild, warranting the death penalty. The Court modified the damages, ordering the accused to pay P75,000.00 as civil indemnity, in addition to the P50,000.00 moral damages and P30,000.00 exemplary damages awarded by the trial court.