People v. Guillermo
REITERATIONFacts
The Antecedents: Mario Guillermo y Esteban was charged with two counts of incestuous rape against his 14-year-old daughter, XXX. The first incident allegedly occurred on November 18, 2000, and the second on April 29, 2001. The victim testified that her father removed her panty while she was sleeping and inserted his organ into hers on the first occasion. On the second occasion, she woke up with her shorts down and her father later admitted to inserting his penis into her, telling her she would not get pregnant. Procedural History: The Regional Trial Court (RTC) of Camiling, Tarlac, Branch 68, found appellant Mario Guillermo y Esteban guilty beyond reasonable doubt of incestuous rape on two counts and sentenced him to suffer the death penalty for each count, with civil indemnity, moral damages, and exemplary damages. Pursuant to People v. Mateo, the case was referred to the Court of Appeals (CA) for appropriate action. The CA dismissed and affirmed the RTC decision. The case was then elevated to the Supreme Court for automatic review. The Petition: The accused-appellant argued that the prosecution failed to prove the fact of carnal knowledge with certainty and that the trial court erred in imposing the death penalty without proving the victim's exact age. He also suggested that his daughter might have been coached by her mother due to ill feelings.
Issue(s)
Whether the prosecution sufficiently proved the fact of carnal knowledge for the crime of rape. Whether the prosecution proved the minority of the victim to warrant the imposition of the death penalty. Whether the penalty imposed by the lower courts was proper in light of subsequent legislation, considering the prohibition of the death penalty and the applicable civil liabilities.
Ruling
The Supreme Court affirmed the conviction for two counts of incestuous rape but modified the penalty. The death penalty was commuted to reclusion perpetua without eligibility for parole, in accordance with R.A. No. 9346. The award for moral damages was increased to ₱75,000.00 for each count.
Ratio Decidendi
On the sufficiency of proof for carnal knowledge: The Court held that the prosecution sufficiently proved carnal knowledge. The victim's testimony was categorical, stating that her father inserted his penis into her vagina. She testified to feeling the insertion and that there was no cloth in between. The Court also noted that the medico-legal report showed healed hymenal lacerations consistent with coitus. The victim's testimony, despite her young age, was given full faith and credit, as is customary in cases involving youthful rape victims. On the proof of minority: The Court found that the minority of the victim was sufficiently proven. The victim's Birth Certificate showed she was fourteen (14) years old at the time of the rape. Furthermore, an Affidavit of Relationship, signed by the appellant and his wife, admitted the birth dates of their children, including the victim. On the propriety of the penalty: The Court acknowledged that the death penalty was initially imposed pursuant to Article 266-B of the Revised Penal Code. However, in view of the passage of R.A. No. 9346, which prohibits the imposition of the death penalty, the Court commuted the sentence to reclusion perpetua without eligibility for parole. The Court reiterated the mandatory awards for civil indemnity (₱75,000.00), moral damages (increased to ₱75,000.00), and exemplary damages (₱25,000.00) for rape committed with qualifying/aggravating circumstances.
Main Doctrine
The Supreme Court affirmed the conviction for incestuous rape on two counts, modifying the penalty from death to reclusion perpetua without eligibility for parole, in light of R.A. No. 9346. The Court also increased the moral damages awarded to the victim.