G.R. No. 133984 - PEOPLE OF THE PHILIPPINES, VS. MEDRILLO RODRIGUEZ, ACCUSED-.D E C I S I O N - Supreme Court E-Library

Ruling

WHEREFORE, finding the accused guilty beyond reasonable doubt of the crime of multiple rape in violation of Article 335 of the Revised Penal Code in relation to Republic Act 7610, the Court hereby sentences him to suffer a prison term of reclusion perpetua , and to indemnify the private complaint the amount of Fifty Thousand (P50,000.00) Pesos. [2] The court, considering the gravity of the offense charged, resolved to set aside its decision and directed the prosecution to prove the guilt of the accused and the precise degree of his culpability. [3] Once it was done, the trial court, in its decision of 22 April 1998, convicted the accused of the crime of rape and meted the capital punishment. Its decretal portions, now up for automatic review, read: WHEREFORE, in view of the foregoing, judgment is hereby rendered finding the accused MEDRILLO RODRIGUEZ guilty beyond reasonable doubt of the crime of rape in violation of Art. 335 of the Revised Penal Code in relation to Republic Act 7659, and the Court hereby sentences him to suffer a penalty of DEATH, and to indemnify the private complainant the amount of Fifty Thousand (P50,000.00) Pesos. Let the records of this case be forwarded to the Honorable Supreme Court for automatic review. [4] The accused would now argue that the trial court gravely erred in ignoring the safeguards expressed in Rule 116 of the 1985 Rules on Criminal Procedure [5] and in not endeavoring to conduct a searching inquiry on the voluntariness and full comprehension of the consequences of the plea of guilty. The court a quo , he claimed, proceeded to accept the plea of guilty without explaining to him in simplest terms the consequences thereof notwithstanding his manifestation to the effect that there was a portion in the complaint which he did not understand. Indeed, Section 3, Rule 116, of the Revised Rules on Criminal Procedure makes it explicit that when the accused pleads guilty to a capital offense, the court is bound to conduct a searching inquiry into the voluntariness and full comprehension of the effects of his plea and to thereupon require the prosecution to prove his guilt and the precise degree of culpability. The searching inquiry, which must be recorded, requires the court to make it indubitably certain that the accused is fully apprised of the consequences of his plea. [6] The court must let the accused realize that a plea of guilty will not, particularly in reference to Republic Act No. 7659, affect or reduce the death penalty as he may otherwise perceive and so come to believe. An accused, not infrequently, would plead guilty in the hope or expectation of a lenient treatment or of a lighter penalty, a situation that should compel the judge to make sure that the accused does not labor under these false impressions. The bottomline rule is that the plea of guilty must be predicated on a free and informed judgment and conviction must not be based on an improvident plea or incriminatory admissions of the accuse