Michael Angok did not apply for bail in Blacktown Local Court on Monday after he was caught in western Sydney while on the run from immigration detention.
He was being transported from Villawood Immigration Detention Centre for medical treatment, before he escaped from Bankstown-Lidcombe Hospital on Wednesday morning.
After some of his personal items were found on the road nearby, police eventually tracked down Angok and arrested him on Sunday.
He was convicted of sexually assaulting a 14-year-old girl in a gang rape at a park in the western Sydney suburb of Doonside in 2014.
The 30-year-old had served his sentence for the offence and was being held in custody as an immigration detainee awaiting deportation.
Opposition home affairs spokesman Jonno Duniam said Angok's case highlighted security at immigration facilities had severely degraded under the government's watch.
"Escapes have more than doubled under Labor in only two years," he said in a statement.
"This points to a system that is clearly not being properly managed."
Home Affairs Minister Tony Burke was contacted for comment.
Immigrants convicted of crimes in Australia detained indefinitely has been a growing legal problem in the past three years, after the High Court found the practice was unlawful.
The ruling prompted the release of more than 200 immigration detainees, known as the NZYQ cohort.
All had finished serving time behind bars, including for serious convictions such as murder and rape, before being held in immigration detention over visa problems.
However, their release sparked a ferocious public response, leading the federal Labor government to rush through laws subjecting them to ankle monitors and curfews - which the High Court later deemed punitive.
Angok will return to court on June 5.
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