GR 155511; (April, 2004) (Digest)
G.R. Nos. 155511-12 EN BANC April 14, 2004
PEOPLE OF THE PHILIPPINES, appellee, vs. MARIO ODEN, appellant.
FACTS
Appellant Mario Oden was charged with twelve counts of rape before the Regional Trial Court of Antipolo City, all involving his fifteen-year-old daughter, Anna Liza Oden. The Informations alleged that the crimes were committed on various dates from August 2000 to January 2001, through force and intimidation. Upon arraignment, appellant, assisted by counsel, pleaded guilty to all charges. The trial court, after conducting a searching inquiry to ensure the voluntariness and comprehension of his plea, accepted it. The court then rendered a judgment finding appellant guilty of twelve counts of qualified rape and imposed the death penalty for each count, citing the minority of the victim and her relationship to the accused as qualifying circumstances.
ISSUE
The core issue for the Supreme Court’s automatic review was whether the death penalty was properly imposed based on the appellant’s plea of guilty, considering the need for conclusive proof of the victim’s minority.
RULING
The Supreme Court affirmed the conviction but modified the penalty. The Court upheld the validity of the appellant’s guilty plea, noting that the trial court conducted a proper searching inquiry as required by jurisprudence. This inquiry established that the plea was made voluntarily, with full understanding of the charges and consequences. However, the Court reduced the penalty from death to reclusion perpetua for each count of rape. The legal logic hinges on the prosecution’s burden to prove the qualifying circumstance of minority with moral certainty to justify the supreme penalty. While the Informations alleged the victim was fifteen, and the appellant admitted this during the plea, the prosecution failed to present independent evidence, such as a birth certificate, to conclusively prove her age was below eighteen at the time of the rapes. Following precedents like People v. Tipay, the Court ruled that the allegation in the Information and the lack of denial by the accused are insufficient to establish minority for purposes of the death penalty. The relationship of father-daughter was duly established by the appellant’s own judicial admission. Thus, the crimes constituted simple, not qualified, rape. The Court also affirmed the awards of civil indemnity and moral damages, and added exemplary damages due to the relationship.