GR 133984; (January, 2002) (Digest)
G.R. No. 133984 ; January 30, 2002
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MEDRILLO RODRIGUEZ, accused-appellant.
FACTS
Accused-appellant Medrillo Rodriguez was charged with the rape of his 16-year-old daughter, Lolibeth Rodriguez, which resulted in her giving birth to a child he admitted to fathering. Initially pleading not guilty, he later changed his plea to guilty through his counsel-de-oficio. The trial court, after accepting the plea, first sentenced him to reclusion perpetua but later set aside this judgment. It then directed the prosecution to present evidence, after which it convicted Rodriguez and imposed the death penalty, prompting this automatic review.
ISSUE
Whether the trial court erred in accepting the accused’s plea of guilty without conducting the requisite searching inquiry and in convicting him of qualified rape punishable by death.
RULING
The Supreme Court modified the trial court’s decision. It ruled that the trial court failed to conduct the mandatory “searching inquiry” under Section 3, Rule 116 of the Revised Rules on Criminal Procedure to ensure the plea of guilty to a capital offense was voluntary and made with full comprehension of its consequences. The recorded exchange showed the accused did not fully understand the charge and even manifested he did not force his daughter, yet the court accepted the plea without adequate explanation, rendering it improvident and legally inconsequential. Furthermore, the Court found the prosecution failed to prove the victim’s minority with the required certainty. While the information alleged she was 16, no independent evidence like a birth certificate was presented. Under prevailing jurisprudence, especially where the age is near majority, such proof is vital for a death-qualifying circumstance. Consequently, the conviction for qualified rape was improper. The Court found Rodriguez guilty of simple rape, sentencing him to reclusion perpetua and ordering him to pay the victim P50,000.00 civil indemnity, P50,000.00 moral damages, and P25,000.00 exemplary damages.