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PEOPLE v. RAFAEL PRINCIPE Y MOLINA

FACTS:

In this case, accused-appellant Rafael Principe y Molina was charged with the rape-slaying of a 6-year-old child, Arlene Ipurong, in Cabanatuan City on August 9, 1998. Accused-appellant pleaded guilty to the charge during his arraignment.

The prosecution presented five witnesses, whose testimonies established the following facts:

Accused-appellant attended a drinking spree and encountered Arlene Ipurong, his niece, who asked if she could share his umbrella. Accused-appellant carried Arlene on his back and went to a restaurant.

At the restaurant, accused-appellant was served by witness Lerma Morales, who noticed the child with him. After getting the "pulutan," accused-appellant took Arlene's hand, and they went towards an abandoned house nearby.

Accused-appellant then ordered Arlene to undress, but she said she would tell someone about it. This angered accused-appellant, who hit Arlene on the forehead with a big rock three times, causing her to lose consciousness. Accused-appellant then raped her and dumped her body into the toilet bowl of the abandoned house.

Accused-appellant returned to the birthday party, missing for about one and a half hours. Arlene's father arrived home and started searching for her. Alfredo Apan, a witness, saw accused-appellant carrying a child earlier and confronted him. Accused-appellant denied being with the child. Apan then suspected accused-appellant's involvement in the disappearance of Arlene and informed the Chief of the Bantay Bayan.

Later that evening, Apan and Arlene's father found her body in the toilet bowl of the abandoned house. An autopsy revealed severe injuries on Arlene's head, caused by fractures, as well as abrasions on her genital area.

Witnesses implicated accused-appellant as the last person seen with Arlene before her death. He was subsequently taken into police custody and admitted to hitting Arlene with a large rock until she lost consciousness and then raping her. Accused-appellant claimed to have been drunk at the time. The trial court found accused-appellant guilty of rape with homicide and sentenced him to death. Accused-appellant appealed, arguing that his guilty plea was not fully apprised of the legal consequences.

ISSUES:

  1. Did the trial court err in convicting the accused of the crime charged despite his improvident plea of guilt?

  2. Whether the circumstantial evidence presented in the case is sufficient to establish the guilt of the accused beyond reasonable doubt.

  3. Whether the trial court correctly imposed the penalty of death.

  4. Whether the trial court correctly awarded the civil indemnity and funeral expenses to the heirs of the victim.

RULING:

  1. The trial court erred in convicting the accused of the crime charged despite his improvident plea of guilt. When an accused enters a plea of guilt to a capital offense, it is the duty of the trial court to conduct a searching inquiry into the voluntariness and full comprehension of the consequences of his plea. In this case, the trial court failed to fully comply with this requirement as it did not ascertain whether the accused was fully apprised of the legal consequences of his plea.

  2. The conviction of the accused based on circumstantial evidence is affirmed. The circumstances presented in the case strongly point to the accused as the perpetrator of the crime. This conclusion is further supported by the accused's extrajudicial confession and his own testimony in open court.

  3. The trial court correctly imposed the penalty of death. The accused knocked the victim unconscious to facilitate the rape and the severity of the blows caused her death. Since the crime of rape was committed by reason or on the occasion of the homicide, the imposable penalty is death.

  4. The trial court erred in fixing the civil indemnity at P50,000.00. However, the court modified the award to P100,000.00 in accordance with previous rulings. The trial court also erred in granting the funeral expenses without proper proof. Instead, the court awarded P15,000.00 as temperate damages to compensate for the undocumented funeral expenses. The court also awarded P50,000.00 as moral damages to the heirs of the victim for the physical suffering, mental anguish, serious anxiety, and moral shock caused by the crime.

PRINCIPLES:

  • A plea of guilt must be based on a free and informed judgment.

  • The trial court must conduct a searching inquiry to determine whether the accused's plea was voluntary and done with full comprehension of the consequences thereof.

  • Mere warning of the supreme penalty of death is insufficient to determine the voluntariness and full comprehension of the accused's plea.

  • An accused may plead guilty in the hope of receiving a lenient treatment or a lighter penalty.

  • While an improvident plea of guilt should be disregarded, the conviction cannot be set aside if there is sufficient and credible evidence on which the judgment of the trial court rests.

  • The admissibility of an extrajudicial confession requires that it be voluntary, made with the assistance of competent and independent counsel, express, and in writing.

  • The conviction of an accused may be based on circumstantial evidence if the requisites of circumstantial evidence are met.

  • The penalty of death may be imposed if the rape is committed by reason or on the occasion of the homicide.

  • The civil indemnity for the heirs of a rape victim shall be not less than P100,000.00 if the homicide is committed by reason or on the occasion of the rape.

  • Funeral expenses must be supported by competent proof, such as receipts, in order to be awarded to the heirs of the victim.

  • In the absence of proof of actual funeral expenses, temperate damages may be awarded as a reasonable amount to compensate for the undocumented expenses.

  • Moral damages may be awarded to the heirs of the victim for the physical suffering, mental anguish, serious anxiety, and moral shock caused by the crime.