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JurisprudenceG.R. No. 252252 -

G.R. No. 252252 - PEOPLE OF THE PHILIPPINES, VS. EDUARDO M. PAGUIO, ACCUSED-.D E C I S I O N - Supreme Court E-Library

Cited Laws

RA 9346
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Decision

Ruling

accordingly, sentenced him to suffer the penalty of reclusion perpetua without eligibility for parole, and ordered him to pay AAA the amounts of P75,000.00 as civil indemnity, P75,000.00 as moral damages, and P30,000.00 as exemplary damages. In so ruling, the RTC found that the prosecution, through AAA's straightforward, credible, and trustworthy testimony, was able to prove that Paguio indeed had carnal knowledge of her against her will and consent. In this regard, the RTC ratiocinated that AAA's clear, categorical, and positive identification of Paguio as the perpetrator outweighed the latter's defenses of denial and alibi. [10] As to the imposable penalty on Paguio, the RTC pointed out that since his use of a deadly weapon to consummate the crime was duly alleged in the information and proven at the trial, he should be penalized with the penalty of death. However, since the death penalty is no longer imposed due to the enactment of Republic Act No. (RA) 9346, [11] he should be penalized instead with reclusion perpetua without eligibility for parole. [12] Aggrieved, Paguio appealed [13] to the CA. The CA Ruling In a Decision. [14] dated June 18, 2018, the CA affirmed Paguio's conviction with modification, increasing the monetary awards due to AAA to P100,000.00 as civil indemnity, P100,000.00 as moral damages, and P100,000.00 as exemplary damages, all with legal interest at the rate of 6% per annum from the date of finality of the ruling until full payment. [15] The CA held that all the elements of the crime have been duly proven, and that there was no cogent or compelling reason to justify a deviation from the findings and conclusions of the RTC, both of which were based on the facts and the law. [16] Hence, this appeal. The Issue Before the Court The issue for the Court's resolution is whether or not Paguio is guilty beyond reasonable doubt of the crime charged. The Court's Ruling The appeal lacks merit. At the outset, it must be stressed that in criminal cases, an appeal throws the entire case wide open for review and the reviewing tribunal can correct errors, though unassigned in the appealed judgment, or even reverse the trial court's decision based on grounds other than those that the parties raised as errors. The appeal confers the appellate court full jurisdiction over the case and renders such court competent to examine records, revise the judgment appealed from, increase the penalty, and cite the proper provision of the penal law. [17] Guided by the foregoing consideration, the Court affirms Paguio's conviction, with modification as to the penalty to be imposed and his civil liability ex delicto , as be explained below. Article 266-A (1) (a) of the RPC reads: Article 266-A. Rape: When And How Committed . Rape is committed: 1) By a man who shall have carnal knowledge of a woman under any of the following circumstances: a) Through force, threat, or intimidation; x x x Thus; the elements of Rape are: ( a ) the offender had carnal knowl