G.R. No. L-34355 July 30, 1979
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ADELANDO RAMOS, alias Bayot, accused.

FACTS

The accused, Adelaido Ramos, was charged with the complex crime of rape with murder for the killing of Leonora Sipalay. The prosecution’s narrative, based on his extrajudicial confession and testimony, established that on August 18, 1971, Ramos, after concocting a story about robbers to isolate Leonora, brought her and her two young children to a secluded hill. There, he made sexual advances. While his confession stated he consummated rape, his subsequent court testimony claimed he only attempted it. After the sexual assault or attempt, Leonora resisted and shouted. To silence her, Ramos hacked her and her two children to death with a bolo, inflicting severe, nearly decapitating wounds. He then fled but was later arrested.
At his arraignment for rape with murder, Ramos, assisted by counsel de oficio, pleaded guilty. The trial judge conducted a searching inquiry, informing him that the charge carried the death penalty, to which Ramos affirmed his plea. Despite this plea, the court still heard his testimony, where he admitted to the killings but claimed only attempted rape. The Circuit Criminal Court of Cebu convicted him of rape with murder, appreciating the mitigating circumstance of plea of guilty but finding it offset by multiple aggravating circumstances, and imposed the death penalty. The case was elevated to the Supreme Court for automatic review.

ISSUE

Whether the trial court erred in convicting Ramos of rape with murder based on his plea of guilty, given his subsequent testimony that he only committed attempted rape.

RULING

The Supreme Court affirmed the conviction but modified the designation of the crime. The Court held that even assuming Ramos’s testimony downgraded the act to attempted rape, the resulting crime would be attempted rape with homicide—a special complex crime under the penultimate paragraph of Article 335 of the Revised Penal Code, as amended. This crime also carries a single, indivisible penalty of death. The legal logic is clear: when the law prescribes a single penalty for a complex crime, it is imposed regardless of the presence of mitigating or aggravating circumstances. Therefore, even if his plea of guilty were considered a mitigating circumstance, it would not alter the prescribed penalty of death. The Court further ruled that the plea was not improvident, as Ramos admitted under oath to all essential elements of at least attempted rape with homicide, which is necessarily included in the charge of rape with murder. Thus, he was fully informed of the accusation. The Court found the crime aggravated by craft, uninhabited place, abuse of superiority, and cruelty. Consequently, the death penalty was upheld, with the modification that the crime is correctly designated as attempted rape with homicide.