GR 252252; (May, 2022) (Digest)
G.R. No. 252252 . June 13, 2022
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. EDUARDO M. PAGUIO, ACCUSED-APPELLANT.
FACTS
This case stemmed from an Information charging Eduardo M. Paguio (Paguio) with Rape. The prosecution alleged that on the evening of May 2, 1999, AAA, then 21 years old, was watching television at her cousin’s house when she saw Paguio looking through the window. Paguio surreptitiously entered, pinned AAA down, removed their clothing, pointed a knife at her neck, threatened to kill her if she shouted, and then had carnal knowledge of her against her will. After the act, Paguio fled. AAA reported the incident to her mother, underwent a medico-legal examination, and reported it to authorities. Paguio denied the accusation, interposing the defenses of denial and alibi. He claimed he was at a friend’s house and later at a plaza watching a fiesta singing contest from the afternoon of May 2 until the early morning of May 3. The Regional Trial Court (RTC) convicted Paguio of Rape and sentenced him to reclusion perpetua without eligibility for parole, ordering him to pay damages. The Court of Appeals (CA) affirmed the conviction but increased the monetary awards.
ISSUE
Whether or not Paguio is guilty beyond reasonable doubt of the crime of Rape.
RULING
Yes, the Supreme Court affirmed Paguio’s conviction but modified the penalty and damages. The Court found that all elements of Rape under Article 266-A(1)(a) of the Revised Penal Code were proven through AAA’s straightforward, credible, and trustworthy testimony, which clearly identified Paguio as her assailant. The Court upheld the findings of the lower courts, noting that no ill motive was shown for AAA to falsely accuse Paguio, and that her testimony deserved full faith and credence. However, the Court corrected the penalty imposed. While the use of a deadly weapon (a knife) was duly alleged and proven, which raises the penalty range to reclusion perpetua to death, the imposition of the death penalty (commuted to reclusion perpetua without parole) was erroneous in the absence of any other aggravating circumstance duly alleged and proven. Thus, the proper penalty is reclusion perpetua. Accordingly, the monetary awards were adjusted to P75,000.00 each as civil indemnity, moral damages, and exemplary damages, all with 6% per annum interest from the finality of the decision until full payment. The appeal was dismissed.