The Supreme Court affirmed the conviction of Documento for two counts of raping his minor daughter. While the trial court failed to conduct a proper searching inquiry regarding Documento's guilty plea, his conviction did not solely rely on the plea and was also supported by sufficient credible evidence presented during the trial. Specifically, the testimony of the victim and other witnesses established that the rapes occurred in Butuan City, giving the trial court proper territorial jurisdiction over the case. Therefore, the failure to conduct a thorough plea inquiry did not warrant reversal of the conviction which was independently supported by evidence presented at trial.
The Supreme Court affirmed the conviction of Documento for two counts of raping his minor daughter. While the trial court failed to conduct a proper searching inquiry regarding Documento's guilty plea, his conviction did not solely rely on the plea and was also supported by sufficient credible evidence presented during the trial. Specifically, the testimony of the victim and other witnesses established that the rapes occurred in Butuan City, giving the trial court proper territorial jurisdiction over the case. Therefore, the failure to conduct a thorough plea inquiry did not warrant reversal of the conviction which was independently supported by evidence presented at trial.
The Supreme Court affirmed the conviction of Documento for two counts of raping his minor daughter. While the trial court failed to conduct a proper searching inquiry regarding Documento's guilty plea, his conviction did not solely rely on the plea and was also supported by sufficient credible evidence presented during the trial. Specifically, the testimony of the victim and other witnesses established that the rapes occurred in Butuan City, giving the trial court proper territorial jurisdiction over the case. Therefore, the failure to conduct a thorough plea inquiry did not warrant reversal of the conviction which was independently supported by evidence presented at trial.
The Supreme Court affirmed the conviction of Documento for two counts of raping his minor daughter. While the trial court failed to conduct a proper searching inquiry regarding Documento's guilty plea, his conviction did not solely rely on the plea and was also supported by sufficient credible evidence presented during the trial. Specifically, the testimony of the victim and other witnesses established that the rapes occurred in Butuan City, giving the trial court proper territorial jurisdiction over the case. Therefore, the failure to conduct a thorough plea inquiry did not warrant reversal of the conviction which was independently supported by evidence presented at trial.
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PEOPLE OF THE PHILIPPINES VS.
DOCUMENTO Issue: G.R. No. 188706 | Nachura | March 17, 2010 1. Whether the RTC had territorial jurisdiction over the crime. – YES Topic: Rule 116 – Arraignment and Plea 2. Whether the failure of the RTC to conduct a Searching Inquiry will result in a reversal of the conviction. - NO Doctrine: A failure to conduct the searching inquiry result in the case being remanded to the trial court only in the improvidently made plea of guilt was Ruling: the sole basis for the conviction. A conviction relying on sufficient and credible evidence will be sustained. 1. Documento insists that the Prosecution failed to establish that the 2 counts of rape were perpetrated in Butuan City. However, it can be Brief Summary: The Accussed was charged and later pled guilty to 2 extrapolated from specific parts of the record that the incidents counts of rape committed against his minor daughter. Before the SC, he occurred in Butuan City. Even if AAA did not specifically mention seeks a reversal of the conviction, arguing that the RTC did not conduct a Butuan City, she made mention of barangays and other places that searching inquiry as prescribed by the guidelines. The SC ruled that were in Butuan City, which the court takes judicial notice of. notwithstanding the failure of the RTC and the improvidently made plea of guilt, the conviction will be sustained as it did not solely rely on the plea of Further, while there were several instances when the rape took guilt. place, the case before the RTC of Butuan was concerned only with the incidents of rape that occurred in Butuan City. Facts: Two Informations were filed against the accused Documento, charging 2. It is true that the RTC failed to conduct the prescribed “searching him to two counts of rape before the RTC of Butuan. inquiry” into the matter of whether Documento’s plea of guilt was The victim was his daughter AAA, 16 years old. improvidently made. The questions propounded were not Upon arraignment, Documento pled not guilty. compliant with the guidelines set for by the High Court and Documento later changed his plea to on of guilt. Documento was not fully apprised of the consequences of his The Prosecution presented the testimonies of AAA, BBB (AAA’s guilty plea. Consequently, Documento’s guilty plea is deemed mother), and Dr. Johann Hugo. improvidently made and thus rendered inefficacious. Documento was the sole witness of the Defense. Documento claims that he pled guilty only because a certain Prosecutor However, this will not mean that the case will be remanded to the Salise convinced him to do so. He further claims that he did not rape RTC. Such an action is proper only when the appellant’s guilty AAA as it had been a consensual sexual relationship. He also alleged plea was the sole basis for the conviction. If the RTC relied of that the incidents did not happen in Butuan City but rather in Misamis sufficient and credible evidence in finding the accused guilty, the Occidental. judgment must be sustained. In this case, Documento’s plea was not the only basis for his conviction. RTC – found Documento guilty beyond reasonable doubt and sentenced him to Death. Dispositive Portion: Wherefore the decision of the CA is AFFIRMED. CA – affirmed the RTC but changed the penalty to Reclusion Perpetua. Documento now appeals before the SC, arguing that the RTC had no territorial jurisdiction and that the RTC failed to conduct a searching inquiry into the voluntariness and full comprehension by the Accused of the consequences of his plea of guilt.
Frank Brooks, Fernando Vitelli, Patricia Vitelli, Edward Turner, and Anne Turner v. John H. Nacrelli, Mayor of The City of Chester, Pennsylvania, 415 F.2d 272, 3rd Cir. (1969)
