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PEOPLE v. FELIPE MIRANDILLA

FACTS:

The case involves accused Felipe Mirandilla, Jr., who was found guilty by the Court of Appeals (CA) of the special complex crime of kidnapping with rape, four counts of rape, and one count of rape through sexual assault. Mirandilla appeals his conviction and claims that he could not have kidnapped and raped the victim, AAA, as they were live-in partners.

AAA narrated her 39-day ordeal at the hands of Mirandilla, starting from the eve of the fiesta in Barangay San Francisco, Legazpi City. She was dancing at a plaza with her sister when she was kidnapped by Mirandilla and his accomplices. They took her to various locations where she was repeatedly raped and sexually assaulted. AAA eventually managed to escape and seek help.

Mirandilla denies the charges against him and claims that he and AAA were in a consensual relationship.

The Regional Trial Court (RTC) found Mirandilla guilty of kidnapping, four counts of rape, and one count of rape through sexual assault. The CA affirmed with modifications the RTC ruling, convicting Mirandilla of the same crimes.

Mirandilla appeals his conviction on the grounds that AAA was not a credible witness and that they were live-in partners.

ISSUES:

  1. Credibility of Prosecution Witness

  2. "Sweetheart Theory" not proven

  3. Did the defense witnesses' contradictory testimonies affect the credibility of their statements?

  4. Did the accused deliberately falsify material points in his testimony?

  5. Whether the separate informations of rape should be considered as separate and distinct crimes.

  6. Whether the penalty of death should be imposed for the special complex crime of kidnapping and serious illegal detention with rape.

  7. Whether the award of civil damages ex delicto is mandatory in a rape case.

  8. Whether the civil indemnity ex delicto of P75,000.00 still applies in cases where the death penalty is not imposed due to R.A. No. 9346.

  9. Whether the victim is entitled to moral damages and exemplary damages.

  10. Whether accused Felipe Mirandilla, Jr. is guilty beyond reasonable doubt of the special complex crime of kidnapping and serious illegal detention with rape.

  11. Whether accused Felipe Mirandilla, Jr. should be sentenced to suffer the penalty of reclusion perpetua without eligibility for parole.

  12. Whether the offended party should be awarded civil indemnity ex delicto, moral damages, and exemplary damages.

RULING:

  1. The trial court found the testimony of the prosecution witness to be credible. The Court of Appeals affirmed this finding, emphasizing that the trial court is in a better position to assess credibility as it had the opportunity to observe the demeanor of the witness. The Supreme Court upheld the trial court's assessment, stating that it is conclusive and binding unless tainted with arbitrariness or oversight. Therefore, the credibility of the prosecution witness was established.

  2. The "sweetheart theory" invoked by the accused was not proven. This theory admits to sexual intercourse but claims it was consensual. However, the burden of proof is on the accused to provide corroborating evidence such as letters, photos, or testimonies from those who knew the alleged lovers. In this case, the accused failed to present sufficient evidence to support the sweetheart theory. Therefore, the theory was not credible and did not absolve the accused of the charges.

  3. The defense witnesses' contradictory testimonies were found to be self-contradictions on material facts, which could not be reconciled. As such, the Court rejected their testimonies and applied the maxim, falsus in uno, falsus in omnibus.

  4. The accused's contradictory statements regarding the nature of his knowledge of AAA's abortion indicated a conscious and deliberate intention to falsify a material point.

  5. The separate informations of rape cannot be considered as separate and distinct crimes because the composite acts are regarded as a single indivisible offense of kidnapping with rape. The special complex crime of kidnapping with rape is punishable by one single penalty.

  6. The penalty of death for the special complex crime of kidnapping and serious illegal detention with rape is reduced to reclusion perpetua without eligibility for parole due to R.A. No. 9346.

  7. The award of civil damages ex delicto is mandatory in a rape case. The civil indemnity ex delicto, restitution, reparation, and indemnification all correspond to actual or compensatory damages in civil law.

  8. The civil indemnity ex delicto of P75,000.00 still applies in cases where the death penalty is not imposed because the qualifying circumstances warranting the penalty of death attended the commission of the offense.

  9. The victim is entitled to moral damages without the necessity of additional pleadings or proof, as well as to exemplary damages. The trauma and sufferings suffered by the victim constitute the basis for moral damages.

  10. Accused Felipe Mirandilla, Jr. is found guilty beyond reasonable doubt of the special complex crime of kidnapping and serious illegal detention with rape.

  11. Accused Felipe Mirandilla, Jr. is sentenced to suffer the penalty of reclusion perpetua without eligibility for parole.

  12. The offended party is awarded the amounts of P75,000.00 as civil indemnity ex delicto, P75,000.00 as moral damages, and P30,000.00 as exemplary damages.

PRINCIPLES:

  • Testimonial evidence must come from a credible witness and be credible in itself, tested by human experience, observation, common knowledge, and accepted conduct. (Daggers v. Van Dyck)

  • The trial court's assessment of a witness' credibility, when affirmed by the Court of Appeals, is conclusive and binding unless tainted with arbitrariness or oversight. (Estioca v. People)

  • The sweetheart theory, as a defense, must be corroborated by documentary, testimonial, or other evidence. (Emphasis supplied)

  • Love is not a license for lust; consent is still required for sexual intercourse.

  • Self-contradictions and contradictory statements of witnesses should be reconciled, except when they involve material facts that cannot be reconciled. In such cases, the Court may reject the testimonies.

  • To completely disregard all the testimony of a witness based on the maxim falsus in uno, falsus in omnibus, the witness's false testimony must pertain to one or more material points and must be accompanied by a conscious and deliberate intention to falsify.

  • An appeal in a criminal case opens the entire case for review on any question, including those not raised by the parties. This is to ensure that law and justice dictate the judgment, regardless of whether it is favorable or unfavorable to the appellant.

  • The crime of kidnapping and serious illegal detention with rape is a special complex crime that requires the presence of both kidnapping and rape elements.

  • The crime of rape is committed through force, threat, intimidation, or by committing an act of sexual assault, such as inserting the penis into another person's mouth or anal orifice, or using any instrument or object on the genital or anal orifice of another person.

  • When the victim is killed or dies as a consequence of the detention or is raped, or is subjected to torture or dehumanizing acts, the maximum penalty shall be imposed, giving rise to a special complex crime.

  • No matter how many rapes had been committed in the special complex crime of kidnapping with rape, the resultant crime is only one kidnapping with rape.

  • The crime of kidnapping with rape requires that the offender should not have taken the victim with lewd designs, otherwise, it would be a complex crime of forcible abduction with rape.

  • Upon the finding of the fact of rape, the award of civil damages ex delicto is mandatory.

  • The civil indemnity ex delicto for the victim shall be in the increased amount of not less than P75,000.00 if the death penalty is imposed, even if the penalty of death is not to be imposed due to R.A. No. 9346.

  • In crimes of rape, moral damages may be awarded to the victim in the criminal proceeding without the need for pleading or proof of the basis thereof.

  • The victim is entitled to exemplary damages in a rape case.

  • The special complex crime of kidnapping and serious illegal detention with rape is punishable under the last paragraph of Article 267 of the Revised Penal Code, as amended by R.A. No. 7659.

  • The penalty for the crime of reclusion perpetua carries with it the accessory penalties provided by law.

  • In cases of kidnapping and serious illegal detention with rape, civil indemnity ex delicto, moral damages, and exemplary damages may be awarded to the offended party.