G.R. No. 135862 ; May 2, 2002
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RAFAEL PRINCIPE y MOLINA, accused-appellant.

FACTS

On August 9, 1998, in Cabanatuan City, accused-appellant Rafael Principe, then 19 years old, attended a drinking session. In the afternoon, he went to buy food, carrying his six-year-old niece, Arlene Ipurong, on his back. Witnesses saw them proceed towards an abandoned house. Inside, Principe ordered the child to undress. When she threatened to tell others, he struck her forehead three times with a big rock, rendering her unconscious. He then raped her and dumped her body into a toilet bowl.
The child’s father reported her missing. A witness informed authorities he had seen Principe with the victim. The child’s body was discovered in the abandoned house that evening. The autopsy confirmed severe cranial injuries and genital abrasions consistent with rape, with the cause of death being severe intracranial injuries. Upon arraignment, Principe, assisted by counsel, pleaded guilty to the charge of rape with homicide.

ISSUE

The core issue is whether the trial court correctly imposed the death penalty upon accused-appellant’s plea of guilty, considering the need to ascertain the precise degree of his culpability and the presence of aggravating circumstances.

RULING

The Supreme Court affirmed the conviction but modified the penalty. A plea of guilty does not automatically justify the imposition of the supreme penalty. The court must still require the prosecution to present evidence to prove the guilt of the accused and the precise degree of his culpability, which the trial court properly did. The evidence, including Principe’s own extrajudicial confession and corroborating testimonies and medical findings, conclusively established the crime of rape with homicide.
The qualifying circumstance of the victim being under eighteen (6 years old) and the offender being a relative by consanguinity or affinity within the third civil degree were present, making the crime punishable by death under Article 266-B of the Revised Penal Code, as amended by Republic Act No. 8353 . However, the Court found the alternative circumstance of minority (Principe being 19) was not appreciated in his favor. Nevertheless, the death penalty was reduced to reclusion perpetua because the information failed to allege with specificity the exact nature of the relationship (that the victim’s paternal grandmother was the sister of the accused’s mother), which is indispensable for imposing the death penalty. The relationship must be alleged with particularity in the information to afford the accused the right to be informed of the nature and cause of the accusation against him.