FACTS:

The case involves accused-appellant Antonio Magat y Londonio who was initially charged with two counts of rape against his daughter, Ann Fideli L. Magat. Accused-appellant pleaded guilty to the charges and entered into a plea bargain agreement, which was accepted by the trial court. The court imposed a penalty of ten years imprisonment for each case. However, the complainant later revived the cases because she considered the penalty imposed to be too light. Accused-appellant was re-arraigned and pleaded not guilty. Trial on the merits proceeded, and the prosecution presented witnesses. Accused-appellant eventually changed his plea to guilty again. The court, convinced of his voluntariness, required the taking of the complainant's testimony. Accused-appellant did not present any evidence. The trial court found accused-appellant guilty of rape beyond reasonable doubt and sentenced him to death for each case. Accused-appellant filed a motion for reconsideration, arguing that the re-arraignment violated his right against double jeopardy and that his initial conviction on his plea of guilt should be final. The trial court denied the motion, prompting the automatic review by the Supreme Court.

During the arraignment, accused-appellant pleaded guilty to the rape charges but requested for a lesser penalty. The trial court allowed the plea and sentenced him to a lesser penalty. However, the Supreme Court found that the accused-appellant's plea was conditional, as he did not plead guilty to a lesser offense but bargained for a lesser penalty. The court emphasized that a plea of guilty should be absolute and unconditional. The judgment based on the void plea bargaining was declared void ab initio, and therefore, double jeopardy does not apply. However, the accused-appellant did not question the procedural errors during the first arraignment, so he is deemed to have waived those errors.

The accused-appellant also argued that the trial court failed to conduct a searching inquiry to ensure that his plea of guilty was voluntary and with a full understanding of the consequences. The Supreme Court stressed the importance of trial courts complying with the procedure laid down in the rules of arraignment, especially for a plea of guilty to a capital offense. The court reminded trial judges to avoid any reasonable doubt about the accused's comprehension of the charges and to ascertain the circumstances surrounding the plea.

ISSUES:

1. Whether the trial court conducted a searching inquiry in accordance with the rules.

2. Whether the absence of the transcript of stenographic notes during the arraignment makes the procedure flawed.

3. Whether the accused-appellant's plea of guilty is sufficient to convict him of the offense charged.

4. Whether the imposition of the death penalty in one of the cases is proper.

5. Whether the award of damages is excessive.

6. Whether or not the death penalty is constitutional.

7. Whether or not the death penalty should be imposed in the present case.

RULING:

1. The trial judge faithfully discharged his duty to determine the voluntariness and full understanding of the accused-appellant's plea of guilt. The judge read the Informations to the accused-appellant, asked him questions regarding his understanding of the consequences of his plea, as well as his educational attainment and occupation. The accused also admitted his guilt in two letters sent to the trial court judge. Therefore, the trial court did conduct a searching inquiry as required by the rules.

2. The absence of the transcript of stenographic notes during the arraignment does not make the procedure flawed. The minutes of the proceedings clearly showed that the trial judge fulfilled his duty to ensure the voluntariness and comprehension of the accused-appellant's guilty plea.

3. The accused-appellant's plea of guilty was validated by his second plea of guilt. Therefore, his guilt was established through the evidence presented by the prosecution, not solely based on his plea. Thus, it cannot be claimed that he was sentenced without being informed of the nature of the charges against him. His failure to present evidence to rebut the prosecution's proof further supports his guilt.

4. The complainant in one of the cases was already nineteen years old when the rape occurred, which does not fall under the provision that warrants the imposition of the death penalty. Therefore, the proper penalty should be reclusion perpetua in that case. However, in another case where the complainant was only seventeen years old, the death penalty is deemed appropriate.

5. The award of compensatory damages should be increased to P75,000.00 in both cases. The trauma, ignominy, pain, and shame suffered by the complainant cannot be regarded any lesser. The award of civil indemnity is justified, especially when the crime is committed by the father against his own child. The award of moral damages should be reduced to P50,000.00 for each count of rape, as it is deemed more reasonable. The award of exemplary or corrective damages is deleted due to the absence of a legal basis.

6. The majority of the Court ruled that the death penalty is constitutional.

7. The Court affirmed the decision of the Regional Trial Court imposing the death penalty in one case, but reduced the penalty to reclusion perpetua in another case.

PRINCIPLES:

• Trial courts are required by the rules to conduct a searching inquiry into the voluntariness and full comprehension of the consequences of an accused's plea of guilt to a capital offense.

• Compliance with the procedure laid down in the rules of arraignment, particularly in cases where the accused pleads guilty to a capital offense, removes any doubt regarding the accused's understanding of the charges and the circumstances surrounding the commission of the crime.

• The evidence taken during the guilty plea proceedings is essential for the fulfillment of the duty of review in automatic appeals from death sentences.

• The absence of a transcript of stenographic notes during the arraignment does not invalidate the procedure if the minutes of the proceedings clearly show that the trial judge conducted a searching inquiry and ensured the voluntariness and comprehension of the accused's plea.

• A plea of guilty may be invalidated if it is proven that the defendant was not fully apprised of the charges against them or if the plea is the sole basis of the judgment. However, if evidence is presented to establish the defendant's guilt independent of the plea, the plea loses legal significance.

• The death penalty can be imposed when the victim is under eighteen years old and the offender is a parent, ascendant, step-parent, guardian, or relative within the third civil degree, or the common-law spouse of the parent of the victim.

• In cases of rape, compensatory damages should be increased if the crime is qualified by circumstances under which the death penalty is authorized. Moral damages may be awarded without the need for pleading or proof of the basis.

• The award of civil indemnity serves as a reaction against heinous crimes against chastity and is especially pronounced when the crime is committed by a parent against their child.

• The Court has the power to declare a law as unconstitutional.

• The Court has the authority to modify a penalty imposed by the lower court.

• The President has the power to exercise executive clemency or pardoning power upon the finality of a decision.