People vs. Apatay

G.R. No. 147965 (July 7, 2004)

Facts:

The case involves Rey Apatay y Balo, who was charged with the crime of Rape with Homicide against 77-year-old Catalina Baluran. The incident occurred on October 20, 2000, in Sikatuna, Bohol, when Apatay, with lewd design and using force, entered the victim's house while she was alone. He turned off the lights, dragged her to a room, and raped her. Fearing that she would identify him, he subsequently attacked her, choking her and striking her head and face with a piece of firewood, resulting in her death. The victim's body was later discovered in an abandoned toilet.

During the arraignment, Apatay, assisted by a public attorney, pleaded guilty to the charges after the Information was read and translated into his native Visayan dialect. The trial court conducted a searching inquiry to ensure that his plea was voluntary and that he understood the consequences of his plea. The prosecution presented evidence, including testimonies from witnesses and a medical examination report confirming the sexual assault and cause of death.

Apatay later surrendered to the police and provided a detailed confession, admitting to the crime and explaining his actions. The trial court found him guilty beyond reasonable doubt and sentenced him to death, along with an order to indemnify the victim's heirs.

Legal Issues:

1. Whether the trial court conducted a proper searching inquiry into the voluntariness and comprehension of the accused's plea of guilty.
2. Whether the trial court erred in not allowing the accused to present evidence in his defense.

Arguments:

• Appellant's Arguments:

  • Apatay contended that the trial court failed to conduct a thorough inquiry into whether he fully understood the implications of his guilty plea.
  • He argued that the court did not ask him if he wished to present evidence in his defense, which he claimed was a violation of his rights.

• Appellee's Arguments:

  • The Solicitor General argued that the trial court properly conducted the necessary inquiries and that Apatay's plea was made voluntarily and with full understanding of its consequences.
  • The prosecution maintained that the evidence presented was sufficient to establish Apatay's guilt and the degree of culpability.

Court's Decision and Legal Reasoning:

The Supreme Court affirmed the trial court's decision, finding that the trial court had complied with the procedural requirements for accepting a guilty plea in a capital offense. The court noted that the trial judge conducted a searching inquiry, confirming that Apatay understood the charges against him, the nature of his plea, and the potential penalty of death. The court emphasized that the judge's inquiries were adequate and that Apatay's responses indicated a clear understanding of the situation.

Regarding the argument about presenting evidence, the court found that the defense had opted not to present any evidence after the guilty plea was entered, which was within their rights. The court also reiterated that the evidence presented by the prosecution, including witness testimonies and the medical report, sufficiently established the elements of the crime.

The court upheld the imposition of the death penalty, citing Article 266-B of the Revised Penal Code, which mandates the death penalty when homicide is committed in the course of rape. The court also awarded civil indemnity to the victim's heirs, including moral and temperate damages, in line with established jurisprudence.

Significant Legal Principles or Doctrines Established:

1. The necessity of a searching inquiry by the trial court when an accused pleads guilty to a capital offense, ensuring that the plea is made voluntarily and with full comprehension of its consequences.
2. The court's discretion in determining the adequacy of the inquiry is based on the specific circumstances of each case, emphasizing the importance of the judge's role in safeguarding the rights of the accused.
3. The affirmation of the death penalty in cases where homicide is committed in the course of rape, reflecting the serious nature of such crimes and the legal framework governing them.