G.R. No. L-35354. April 5, 1982.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. LIANI ARARAO, defendant-appellant.

FACTS

In the evening of February 26, 1970, three armed men entered the house of Julia Mariquit in Lanao del Norte through a window. The intruders, one of whom was the appellant Liani Ararao—a former boarder in the house—assaulted Julia and her daughter, Jovencia Tesio. They demanded money, and upon being shown a box, stole cash and personal properties. During this robbery, the two male companions of Ararao took turns raping the 65-year-old Julia Mariquit while she was pinned to the floor. Simultaneously, inside another room, Ararao himself raped Jovencia Tesio at knifepoint after tearing her clothing. The victims positively identified Ararao due to his prior residence in their home. An information was filed charging Ararao with the complex crime of Robbery with Rape under Article 294(2) of the Revised Penal Code, with aggravating circumstances.

ISSUE

The core legal issue is whether the appellant was correctly convicted of the special complex crime of robbery with rape, or if the facts and information instead support a conviction for a different complex crime involving robbery with force upon things.

RULING

The Supreme Court affirmed the conviction for the special complex crime of robbery with rape. The Court meticulously analyzed the allegations in the information and the evidence presented. It held that the information sufficiently charged robbery with rape, as it explicitly alleged that the rape was committed “on the occasion of the said robbery.” The evidence conclusively proved that the taking of personal property and the rapes were part of a single criminal episode, executed by a band of malefactors acting in concert. The Court rejected the appellant’s arguments and the view in a separate opinion that the crime should be classified as a complex crime under Article 48 of the Revised Penal Code (combining robbery with force upon things under Article 299 and robbery with rape under Article 294). The majority maintained that robbery with rape, as defined in Article 294(2), is a single, special, and indivisible offense, not a compound or composite crime under Article 48. The rapes were not merely incidental but were integral acts of violence and intimidation employed to facilitate the robbery. The penalty of reclusion perpetua was thus correctly imposed, with due consideration given to the aggravating circumstances of nighttime and dwelling. The Court also affirmed the awards for indemnity and damages to the victims.