G.R. No. L-60559 December 2, 1987
People of the Philippines vs. Benjamin Puzon y Marcaida

FACTS

The accused-appellant, Benjamin Puzon, was charged with rape with robbery. The information alleged that on April 9, 1979, in Pasig, Metro Manila, he used force, intimidation, and a gun to have carnal knowledge of Cayleen Kahayon against her will and, on the same occasion, stole P600.00 from her. The prosecution evidence detailed that Puzon, posing as a wealthy doctor named “Arturo Yupangco,” deceived the victim over several days. On the night of the crime, he offered to take her to work but instead directed a taxi to Pasig. Inside the taxi, he embraced her, showed a gun, and threatened to blow her head off. He then brought her to the Orchids Motel, where, at gunpoint, he forced her into a room and raped her. After the act, he took P600.00 from her wallet.
The accused initially pleaded not guilty but later changed his plea to guilty. The trial court, however, did not immediately sentence him. Instead, it required the prosecution to present evidence, including the testimony of the victim, to fully establish the details and circumstances of the crime. After evaluating this evidence, the Circuit Criminal Court found him guilty and imposed the death penalty, leading to this automatic review.

ISSUE

The core issue is whether the trial court erred in convicting the accused based on his plea of guilt and in imposing the death penalty.

RULING

The Supreme Court affirmed the conviction but modified the penalty to reclusion perpetua. The legal logic is twofold. First, the conviction was not based solely on the plea of guilt, which renders the cited ruling in People v. Nismal inapplicable. The Nismal doctrine requires setting aside a conviction only when the plea is the sole basis for a judgment in a capital offense. Here, the trial court prudently required the prosecution to present full evidence despite the plea. The victim’s credible testimony, corroborated by a medico-legal report and evidence of a consistent modus operandi in other cases, provided more than sufficient independent proof of guilt. Thus, the plea was not improvident, and the conviction stands on solid evidentiary ground.
Second, the modification of the penalty is constitutionally mandated. The death penalty was imposed by the trial court in 1979. However, the 1987 Constitution , which took effect prior to this review, prohibits the imposition of the death penalty unless Congress provides for it for certain heinous crimes. At the time of this decision, no such law was enacted. Consequently, the Supreme Court applied Article III, Section 19(1) of the 1987 Constitution , commuting the death sentence to the penalty of reclusion perpetua. The award of moral damages was likewise sustained.