Cited Laws
TL;DR — Ruling
WHEREFORE , premises considered, the Court finds accused Edgardo Z. Antonio GUILTY beyond reasonable doubt of the crime of rape and hereby sentences him to suffer the penalty of DEATH and to pay victim AAA the amount of Php 75,000.00 by way of civil liability. SO ORDERED .
WHEREFORE , premises considered, the Court finds accused Edgardo Z. Antonio GUILTY beyond reasonable doubt of the crime of rape and hereby sentences him to suffer the penalty of DEATH and to pay victim AAA the amount of Php 75,000.00 by way of civil liability. SO ORDERED . [3] The case was elevated to this Court on automatic appeal but was remanded to the Court of Appeals in accordance with People v. Mateo . [4] The Court of Appeals affirmed the decision of the trial court with modification. [5] Pursuant to Republic Act (RA) 9346, [6] it reduced the imposed penalty from death to reclusion perpetua without eligibility for parole. Invoking RA 9346, it also lowered the civil indemnity from P75,000 to P50,000. Moreover, in accordance with prevailing jurisprudence, it awarded P50,000 moral damages to the offended party. Considering that the crime was aggravated by AAA's minority, exemplary damages of P25,000 were also granted. The dispositive portion of the decision read: WHEREFORE , Decision of conviction dated 2 April 2004 rendered by the Regional Trial Court of Baler, Aurora, Branch 96 is AFFIRMED with MODIFICATION in that the accused-appellant Edgardo Z. Antonio is hereby sentenced to suffer the penalty of reclusion perpetua and to pay AAA civil indemnity in the amount of P50,000.00; moral damages in the amount of P50,000.00; and exemplary damages in the amount of P25,000.00. SO ORDERED . [7] After appellant, through the Public Attorney's Office, filed a timely notice of appeal, the Court of Appeals forwarded the records of the case to this Court. We deny the appeal. Both the trial and appellate courts gave credence to the testimony of AAA. She categorically pointed to appellant as the one who violated her. In connection with the crime, she candidly testified on what appellant did to her and the details thereof. For this reason, both the trial and appellate courts found that appellant's guilt for the crime of qualified rape (that is, rape qualified by any of the circumstances under which the death penalty could have been imposed had not RA 9346 prohibited it) [8] was sufficiently established beyond reasonable doubt. This Court finds no compelling reason to rule otherwise. The Court of Appeals correctly reduced the penalty imposed on appellant from death to reclusion perpetua without eligibility for parole in accordance with RA 9346. However, it erred in lowering the civil indemnity from P75,000 to P50,000 purportedly in accordance with the same law. The law only prohibited the imposition of the death penalty but did not affect the corresponding pecuniary or civil liabilities. In People v. Bejic , [9] the penalty imposed on the accused who was convicted of qualified rape was downgraded from death to reclusion perpetua without eligibility for parole under RA 9346. Discussing the corresponding liability for civil indemnity, the Court ruled: The award of civil indemnity in the amount of P75,000.00 is the correct amount to be awarded if the crime is qu
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