People v. De Guzman
REITERATIONFacts
The Antecedents: Two Informations were filed on March 2, 2005 charging the accused with two counts of Statutory Rape under Article 266-A(1)(d) of the Revised Penal Code. The prosecution alleged two separate incidents occurring on May 7, 2003 and June 17, 2003 involving the same minor victim identified in the record as "AAA," who was a nine (9) year old and a niece by affinity of the accused. The accused admitted familial relationship and residence in the victim's house but denied the charges, asserting alibi and denial. Procedural History: The Regional Trial Court, Branch 72, Antipolo City, in a Decision dated September 15, 2015 convicted the accused of two counts of Statutory Rape and sentenced him to reclusion perpetua for each count, and awarded damages. On appeal, the Court of Appeals in a Decision dated June 29, 2017 affirmed with modifications (increasing exemplary damages and imposing legal interest). The People appealed to the Supreme Court, which promulgated its Decision on October 1, 2018. The Petition: The accused appealed to the Court of Appeals, which affirmed the conviction; the accused then appealed to the Supreme Court contending, inter alia, that his conviction should not be upheld.
Issue(s)
Whether the conviction for two counts of Statutory Rape should be upheld. Whether the facts support upgrading the conviction to two counts of Qualified Statutory Rape. Whether the penalty of reclusion perpetua without eligibility for parole applies under Republic Act No. 9346. Whether the awards of civil indemnity, moral damages, exemplary damages, and legal interest should be modified.
Ruling
The appeal is denied. The Decision dated June 29, 2017 of the Court of Appeals in CA-G.R. CR HC No. 08332 is affirmed with modifications: the accused is found guilty beyond reasonable doubt of two counts of Qualified Statutory Rape under Article 266-A(1)(d) in relation to Article 266-B(1) of the Revised Penal Code; sentenced to suffer reclusion perpetua without eligibility for parole for each count; ordered to pay the victim P100,000.00 as civil indemnity, P100,000.00 as moral damages, and P100,000.00 as exemplary damages for each count, with legal interest of six percent (6%) per annum from finality until full payment.
Ratio Decidendi
On Issue 1: Whether the conviction for two counts of Statutory Rape should be upheld. The Court observed that an appeal in criminal cases opens the entire case for review and that the appellate tribunal has full jurisdiction to examine the records and correct errors, citing People v. Comboy (G.R. No. 218399, March 2, 2016) for the principle that an appellate court may revise judgments and increase penalties. The Court found that the prosecution established beyond reasonable doubt the essential elements of Statutory Rape: the age of the victim, the identity of the accused, and the occurrence of sexual intercourse. The trial court had the primary opportunity to observe the demeanor and credibility of witnesses, and the Supreme Court accorded due deference to those factual findings because there was no indication that the trial court overlooked or misunderstood the surrounding facts and circumstances. Given the victim's straightforward and categorical testimony identifying the accused and the corroborating circumstances, the Court concluded that the conviction should be upheld. Consequently, the conviction was sustained, subject to the legal qualification discussed next. On Issue 2: Whether the facts support upgrading the conviction to two counts of Qualified Statutory Rape. The Court analyzed Articles 266-A(1)(d) and 266-B(1) of the Revised Penal Code and explained that statutory rape is committed where a man has carnal knowledge of a woman under twelve (12) years of age regardless of consent, and that the rape shall be qualified if the victim is under eighteen (18) years old and the offender is a relative by consanguinity or affinity within the third civil degree. Applying those provisions to the proven facts — that the victim was nine years old and that the accused was her uncle by affinity — the Court determined that the qualifying circumstance under Article 266-B(1) was present. The Court emphasized that the elements necessary for Qualified Statutory Rape were proven by the prosecution through positive and categorical testimony and supporting circumstances. Therefore, the Court found it proper to upgrade the conviction from Statutory Rape to Qualified Statutory Rape for both counts. On Issue 3: Whether the penalty of reclusion perpetua without eligibility for parole applies under Republic Act No. 9346. The Court noted that Republic Act No. 9346 abolished the death penalty and provided that persons convicted of offenses punished with reclusion perpetua, or whose sentences will be reduced to reclusion perpetua by reason of the Act, shall not be eligible for parole under the Indeterminate Sentence Law. Citing Section 3 of RA 9346 and Section 2 regarding its operation, the Court concluded that the accused must be sentenced to reclusion perpetua without eligibility for parole for each count of Qualified Statutory Rape. The Court thus imposed reclusion perpetua per count with the express prohibition on parole as required by RA 9346. The ruling follows the statutory mandate and prevailing jurisprudence implementing RA 9346. On Issue 4: Whether the awards of civil indemnity, moral damages, exemplary damages, and legal interest should be modified. The Court reviewed the awards of damages and prevailing jurisprudence on compensation for victims of sexual crimes and found it proper to increase each category of damages to P100,000.00 per count given the gravity of the offense and the victim's circumstances. The Court also affirmed the imposition of legal interest at the rate of six percent (6%) per annum from the finality of the decision until full payment, consistent with practice in similar cases. The modification of damages was justified to afford the victim adequate reparation and to serve as deterrence. Accordingly, the Court increased the awards previously given and ordered interest to ensure timely satisfaction of the monetary awards.
Main Doctrine
Conviction for Statutory Rape may be upgraded to Qualified Statutory Rape where the victim is under 18 and the offender is a relative by consanguinity or affinity within the third civil degree; appellate court may modify conviction and impose appropriate penalties and damages; persons sentenced to reclusion perpetua under RA 9346 are not eligible for parole.