G.R. No. 252861 . February 15, 2022.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. ALEXANDER OLPINDO Y REYES, ACCUSED-APPELLANT.

FACTS

On October 6, 2008, Alexander Olpindo y Reyes (accused-appellant) was charged with rape in relation to R.A. No. 7610 for an incident on February 27, 2008, in San Jose City. The information alleged that by means of force, violence, and intimidation, he had carnal knowledge of AAA, a 14-year-old minor. After evading arrest, he was apprehended on December 4, 2012, pleaded not guilty, and trial ensued.
The prosecution’s version, based on AAA’s testimony, stated that on February 27, 2008, around 7:00 p.m., AAA and her sister BBB were accosted by accused-appellant and his sister Mary Ann while on a tricycle. They forced AAA aboard, drove to Barangay X, and accused-appellant took her to an uninhabited place. There, he tied her hands, slammed her to the floor, removed her clothes and his, and inserted his penis into her vagina, causing her pain. Afterward, he untied her, warned her not to tell anyone, but she reported it to her aunt the next day. A medico-legal report was stipulated.
The defense claimed AAA was accused-appellant’s girlfriend and that their sexual relations were consensual. He testified he fetched AAA and his sister from the market that night, dropped them off, and later was confronted by police after AAA’s family complained. He alleged AAA’s grandmother forced her to file the rape charge due to their opposed relationship. A defense witness stipulated they were neighbors and appeared happy when fetched.
The Regional Trial Court (RTC) found accused-appellant guilty of rape under Article 266-A of the Revised Penal Code, sentenced him to reclusion perpetua, and ordered him to pay damages. The RTC forwarded the records to the Court of Appeals (CA) for automatic review, citing People v. Mateo. The CA noted that since the penalty was reclusion perpetua and not death, automatic review did not apply, and the judgment would have been final due to the lack of a notice of appeal. However, the CA proceeded to review the case as if an appeal was filed, affirmed the RTC’s conviction, but did not modify the damages, stating the RTC decision had attained finality. Accused-appellant appealed to the Supreme Court.

ISSUE

The main procedural issue was whether the CA correctly reviewed the RTC decision despite the lack of a timely notice of appeal, given the imposition of reclusion perpetua and the inapplicability of automatic review under R.A. No. 9346 . The substantive issues raised by accused-appellant pertained to the credibility of AAA’s testimony, the sufficiency of evidence to prove rape, and the disregard of his defense of denial and alibi.

RULING

The Supreme Court affirmed the conviction but modified the damages. The Court held that the CA erred in stating the RTC decision had become final and executory. Under Rule 122, Section 3(c) of the Rules of Court, a judgment imposing reclusion perpetua is appealed by filing a notice of appeal with the trial court. The RTC’s act of forwarding the records for automatic review was incorrect, as automatic review applies only to death penalty cases, which are prohibited under R.A. No. 9346 . However, since accused-appellant filed a motion for reconsideration within the reglementary period, the period to appeal was suspended. His subsequent appeal to the CA, though initially lacking a notice of appeal, was treated as a petition for review under Rule 42, and the CA properly assumed jurisdiction. Thus, the appeal was timely.
On the merits, the Court found accused-appellant guilty beyond reasonable doubt of rape under Article 266-A(1) of the Revised Penal Code. AAA’s credible, straightforward, and consistent testimony, corroborated by the medico-legal findings, established all elements of rape through force and intimidation. The defense of consensual sex and denial was weak, self-serving, and uncorroborated. Flight and evasion of arrest further indicated guilt. The Court increased the damages in accordance with People v. Jugueta: civil indemnity to P75,000, moral damages to P75,000, and exemplary damages to P75,000, all with 6% interest per annum from finality until full payment.