GR 174056; (February, 2007) (Digest)
G.R. No. 174056 ; February 27, 2007
THE PEOPLE OF THE PHILIPPINES, Appellee vs. ROGELIO GUMIMBA y MORADANTE alias ROWING and RONTE ABABO (acquitted), Appellants.
FACTS
Appellant Rogelio Gumimba was charged with the rape with homicide of his eight-year-old niece. Initially pleading not guilty, he later changed his plea to guilty during trial. The prosecution presented witnesses, including barangay officials, to whom Gumimba had voluntarily confessed that he alone raped and killed the victim. Medical testimony confirmed the victim sustained fatal stab wounds and genital lacerations consistent with rape. During the trial, Gumimba, presented as a witness against his co-accused Ronie Abapo, recanted his earlier exclusive confession and implicated Abapo. The trial court, however, found this subsequent testimony unworthy of credence.
ISSUE
The core issue is whether the trial court correctly accepted Gumimba’s plea of guilty and convicted him based on this plea and the corroborative evidence, despite his later testimony implicating another.
RULING
The Supreme Court affirmed the conviction. A plea of guilty, when voluntarily made with full comprehension of its consequences, is a judicial admission of all the facts alleged in the information. The trial court meticulously conducted a searching inquiry to ensure Gumimba understood the gravity of his plea and the mandatory death penalty it carried at the time. This inquiry satisfied the legal requirement for voluntariness and intelligence. His judicial confession, coupled with the overwhelming corroborative evidence—including his detailed extrajudicial confessions to barangay officials and the medico-legal findings—conclusively established his guilt beyond reasonable doubt.
The Court ruled that Gumimba’s later attempt to retract his plea and shift blame to Abapo was a mere afterthought, rightly disregarded by the lower courts. A plea of guilty is a stronger evidence of guilt than testimony offered subsequently for acquittal. The conviction for the special complex crime of rape with homicide was thus upheld. However, pursuant to Republic Act No. 9346 , the death penalty was reduced to reclusion perpetua without eligibility for parole. The awarded damages were also modified in line with prevailing jurisprudence.