G.R. No. 167179 ; January 28, 2008
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ELMER CEREDON y PAGARAN, accused-appellant.

FACTS

Accused-appellant Elmer Ceredon was charged with ten counts of rape committed against his younger sister, AAA, from 1995 to 2000. The Informations uniformly alleged that he, armed with a knife and by use of force and intimidation, had carnal knowledge of the victim against her will. Initially pleading not guilty at arraignment, the appellant, through counsel, later manifested his desire to change his plea to guilty for all charges during the pre-trial conference. The trial court granted this and re-arraigned him, after which a joint trial on the merits proceeded.
During trial, the prosecution presented the victim, AAA, and her teacher. AAA testified in detail about the repeated sexual assaults, describing the use of a knife and threats to kill her if she reported the incidents. The defense presented no evidence. The Regional Trial Court convicted the appellant of ten counts of rape and initially imposed the death penalty for each count, which was automatically reviewed by the Supreme Court.

ISSUE

The core issue is whether the trial court committed reversible error in convicting the accused-appellant based on his change of plea to guilty and the evidence presented, and in imposing the proper penalty following the repeal of the death penalty.

RULING

The Supreme Court affirmed the conviction but modified the penalty. The Court held that a plea of guilty, especially in a capital offense, does not automatically result in conviction; the prosecution must still prove the accused’s guilt and the precise degree of culpability beyond reasonable doubt. Here, the requisites of rape were sufficiently established. AAA’s categorical and consistent testimony, corroborated by her teacher’s account of the victim’s distressed behavior, proved all elements of the crime: carnal knowledge through force or intimidation, with the aggravating circumstances of minority and relationship. The use of a deadly weapon and the victim being under eighteen and the offender’s sister were properly alleged and proven.
Regarding the penalty, the crimes were committed before the enactment of Republic Act No. 9346 , which prohibited the imposition of the death penalty. Applying the rule that a favorable penal law has retroactive effect, the Court modified the sentences. For each count of rape qualified by minority and relationship, the prescribed penalty is reclusion perpetua to death. With the abolition of the death penalty, and with no mitigating or aggravating circumstances modifying the liability, the penalty for each count is reduced to reclusion perpetua. The appellant was thus sentenced to ten penalties of reclusion perpetua, with corresponding civil indemnities, moral damages, and exemplary damages awarded to the victim.