GR 176634; (April, 2010) (Digest)
G.R. No. 176634 ; April 5, 2010
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. ROMEO MIRANDA y MICHAEL, Accused-Appellant.
FACTS
Accused-appellant Romeo Miranda was charged with the rape of his 17-year-old daughter, AAA. The prosecution established that on June 24, 2000, in Pateros, Metro Manila, AAA was staying at her father’s house. While she was ill with a fever, Miranda massaged her, touched her breasts, and forcibly performed cunnilingus on her. He then proceeded to have sexual intercourse with her despite her resistance. A medico-legal examination confirmed fresh lacerations and the presence of seminal fluid, consistent with recent penetration. The defense, relying on denial and alibi, claimed Miranda was elsewhere at the time.
The Regional Trial Court found Miranda guilty beyond reasonable doubt of rape and initially imposed the death penalty, which was automatically reviewed. The Court of Appeals affirmed the conviction but modified the penalty to reclusion perpetua, as the requisite minority and relationship were established not during trial but via a pre-trial stipulation of facts, which precluded the imposition of the death penalty under prevailing jurisprudence at the time. The CA also adjusted the awards for damages.
ISSUE
Whether the Court of Appeals correctly affirmed Miranda’s conviction for qualified rape and imposed the penalty of reclusion perpetua without parole.
RULING
Yes, the Supreme Court affirmed the conviction with modification. The Court upheld the factual findings of the lower courts, emphasizing that the victim’s credible and categorical testimony, corroborated by medical evidence, sufficiently established all elements of rape. The defense of denial and alibi, unsubstantiated by clear and convincing evidence, could not prevail over the positive identification by the victim.
Regarding the penalty, the Supreme Court sustained the reduction to reclusion perpetua. The qualifying circumstances of minority and relationship, while admitted in the pre-trial stipulation, were not proven during trial as required by the Court’s ruling in People v. Garcia. Consequently, the death penalty could not be imposed. However, since the crime is qualified rape punishable by reclusion perpetua to death, the proper penalty is reclusion perpetua without eligibility for parole, pursuant to Section 3 of Republic Act No. 9346 . The Court also modified the damages, increasing exemplary damages to ₱30,000.00 in accordance with prevailing jurisprudence, while affirming civil indemnity and moral damages at ₱75,000.00 each.