G.R. No. 64499 . March 6, 1984.
THE PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. FAUSTINO MARTINEZ y LALONGISIP alias FAUSTO, Accused.

FACTS

Faustino Martinez, a convict serving a sentence for homicide and detained at the provincial jail in Calapan, Oriental Mindoro, was inexplicably allowed by a provincial guard to gather firewood in Victoria and was not returned to custody. On the evening of May 18, 1983, during a barangay dance, Martinez met Merle Aquino, an 18-year-old acquaintance. After the dance, Martinez escorted her home. On the way, he forcibly brought her to a coconut grove, raped her, and subsequently stabbed her to death when she threatened to report the assault to her father. The victim sustained nineteen stab wounds, one fatal, and autopsy confirmed sexual assault with violent laceration.
At his arraignment for the complex crime of rape with homicide, Martinez, assisted by counsel, voluntarily pleaded guilty after being duly informed by the trial judge that the plea would result in the imposition of the death penalty. The court, taking judicial caution, still required the prosecution to present evidence. Martinez later testified, ratifying his extrajudicial confession and reaffirming his guilt. The trial court convicted him and imposed the death penalty, prompting this automatic review.

ISSUE

Whether the trial court correctly imposed the death penalty upon the accused who pleaded guilty to the special complex crime of rape with homicide.

RULING

Yes, the Supreme Court affirmed the imposition of the death penalty. The legal logic is anchored on the mandatory nature of the penalty for the special complex crime of rape with homicide under Article 335 of the Revised Penal Code, as amended by Republic Act No. 4111 . The Court, citing established jurisprudence such as People v. Pascual, Jr., ruled that for this specific crime, the penalty is death, to be imposed regardless of the presence of generic mitigating or aggravating circumstances. The plea of guilty, while a mitigating circumstance under ordinary crimes, is not considered in the imposition of the penalty for this special complex offense. The Court found that the plea was entered voluntarily, intelligently, and with full assistance of counsel, as the accused was explicitly apprised of its consequences. The judicial requirement for the prosecution to present evidence despite the plea further ensured the correctness of the conviction. Thus, no reversible error attended the trial court’s judgment. The Court, however, noted the administrative anomaly of the accused’s unauthorized liberty and directed a copy of the decision to the Minister of Justice for appropriate action.