G.R. No. L-70742 August 19, 1986
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RICARDO AGUIRRE y MANAPING alias “Palakit,” defendant-appellant.

FACTS

Ricardo Aguirre was charged with rape with homicide for the death of Lolita Cabel on June 3, 1984, in Quirino, Ilocos Sur. The information alleged that he used force and intimidation to have carnal knowledge of the victim and, on the occasion thereof, assaulted her with a stone, causing fatal injuries. Upon arraignment before the Regional Trial Court, Aguirre, assisted by counsel de oficio, pleaded guilty. The court, noting the gravity of the complex offense, directed the prosecution to present evidence to prove the commission of the crime and the precise degree of culpability. The prosecution presented testimonial and documentary evidence, including two extrajudicial confessions executed by Aguirre. The trial court rendered a judgment of conviction and imposed the death penalty.
On automatic review, counsel de oficio raised several errors. He argued that Aguirre did not fully comprehend the consequences of his guilty plea, that his extrajudicial confessions were inadmissible for non-compliance with constitutional procedures on custodial investigation, that the element of rape was not proven beyond reasonable doubt, and that mitigating circumstances should reduce the penalty from death.

ISSUE

The primary issues were: (1) the validity of Aguirre’s guilty plea; (2) the admissibility of his extrajudicial confessions; (3) the sufficiency of evidence proving rape with homicide; and (4) the propriety of the death penalty.

RULING

The Supreme Court affirmed the conviction but modified the penalty. The Court held that the trial court did not err in accepting the guilty plea. While the original inquiry into the voluntariness of the plea was brief, the subsequent full-blown trial where the prosecution presented its entire evidence and Aguirre was given the opportunity to cross-examine witnesses and present his own defense cured any procedural defect. This trial effectively substituted for a searching inquiry, ensuring the plea was intelligently made.
Regarding the confessions, the Court found they were obtained in violation of Aguirre’s constitutional rights, specifically the right to counsel and to be informed thereof, as mandated in Morales v. Ponce Enrile. They were thus inadmissible for being constitutionally infirm. However, the conviction did not rest on these confessions. The Court found the remaining evidence—particularly the dying declaration of the victim identifying Aguirre as her rapist and assailant, the corroborative testimony of witness Gregorio Cabel, and the medico-legal findings—sufficient to establish Aguirre’s guilt for the complex crime of rape with homicide beyond reasonable doubt.
On the penalty, the Court ruled that the death penalty was improper. The complex crime of rape with homicide under Article 335 of the Revised Penal Code, as amended by Presidential Decree No. 767, carries the penalty of reclusion perpetua to death. Since no aggravating circumstance was proven to justify the imposition of the supreme penalty, the lesser penalty of reclusion perpetua was correctly applicable. The award of damages was also modified to conform with prevailing jurisprudence.