G.R. No. 136382 , June 25, 2001
People of the Philippines, plaintiff-appellee, vs. Fidel Alborida y Villegas, accused-appellant.

FACTS

Accused-appellant Fidel Alborida was charged with the rape of his eight-year-old daughter, Suzette C. Alborida, on or about June 13, 1998, in Los Baños, Laguna. Initially pleading not guilty, he later changed his plea to guilty during a pre-trial conference. The trial court confirmed his intent to change the plea and proceeded to accept it. Despite the guilty plea, the prosecution presented evidence, including the testimony of the victim and the examining physician. Suzette testified that on the night of June 13, 1998, while she was sleeping, her father transferred her to his bed, undressed her, and inserted his penis into her vagina, causing her pain. He also inserted his finger after applying soap. Her mother arrived, and Suzette reported the incident, leading to the filing of the case. She also revealed four prior molestations. The medical examination showed abrasion, redness, and a hymenal laceration. The trial court found accused-appellant guilty beyond reasonable doubt and imposed the death penalty, along with an award of moral damages.

ISSUE

Whether the trial court erred in not applying the safeguards required for a plea of guilty to a capital offense under Rule 116, Section 3 of the Revised Rules on Criminal Procedure.

RULING

The Supreme Court held that the trial court failed to conduct the required “searching inquiry” into the voluntariness and full comprehension of accused-appellant’s guilty plea. The questions asked by the trial judge—confirming the change of plea, awareness of the death penalty, and absence of intimidation—were insufficient to constitute a proper searching inquiry as mandated by the rules. The Court cited precedents emphasizing that a mere warning about the death penalty is inadequate; the judge must thoroughly ensure the accused understands the consequences, including inquiries into the accused’s arrest, detention, assistance of counsel, age, educational attainment, and socio-economic status. However, despite the improvident plea, the Court did not remand the case because the prosecution’s evidence, particularly the credible testimony of the victim and the medical findings, proved accused-appellant’s guilt beyond reasonable doubt. The death penalty was affirmed, but the civil indemnity was increased to P75,000.00 in line with prevailing jurisprudence. The records were ordered forwarded to the Office of the President for possible exercise of pardoning power.