G.R. No. L-32422. March 2, 1984.
THE PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. JUAN CRISOLA, Defendant-Appellant.

FACTS

The accused, Juan Crisola, then sixty-nine years old, was convicted of the crime of rape against seven-year-old Purisima Machica and sentenced to reclusion perpetua. The prosecution evidence established that on November 1, 1968, Crisola brought the child to a house in Quezon City, where he sexually assaulted her. The victim provided a clear and straightforward account of the painful incident. Her testimony was corroborated by her mother, Rosita Machica, who, upon being informed by a neighbor, examined her daughter and found physical signs of swelling. When confronted, Crisola asked for forgiveness and promised to pay for hospital treatment before disappearing until his arrest in 1969.
During the appeal, a significant development occurred. The President of the Philippines granted executive clemency, commuting Crisola’s sentence to an indeterminate prison term of 14 years, as minimum, to 19 years, as maximum, and ordering him to pay an indemnity. It was further reported that due to his advanced age and having served his minimum sentence, he was on parole and residing in a home for the aged.

ISSUE

Whether the appeal from the judgment of conviction for rape should be dismissed in light of the grant of executive clemency and the sufficiency of the evidence establishing guilt beyond reasonable doubt.

RULING

The Supreme Court dismissed the appeal. The legal logic proceeds from two key points. First, the grant of commutation by the President, an exercise of the constitutional pardoning power, is binding and effective. This executive act alone serves to put an end to the appeal, as it modifies the penalty imposed by the lower court. Notwithstanding this, the Court addressed the merits of the conviction for finality and the appellant’s peace of mind.
On the merits, the Court found the conviction was in accordance with law. The trial court correctly gave credence to the clear, positive, and straightforward testimony of the child victim, which was corroborated by her mother. The defense of alibi and weak denial offered by Crisola, who even stated “I do not have my erection anymore” rather than providing a categorical denial of the act, could not prevail. The evidence successfully overcame the presumption of innocence and proved guilt beyond reasonable doubt. Thus, no justification existed for a reversal of the judgment of conviction.