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PEOPLE v. ROBERTO HIDALGO

FACTS:

Facts:

Accused Roberto Hidalgo and his son Don Juan Hidalgo were both charged with three counts of simple rape under the "Anti-Rape Law of 1997." The charges were based on incidents that occurred on January 30, 2000, where the accused allegedly conspired and mutually helped each other in forcibly having sexual intercourse with their thirteen-year-old household helper. The information for each count of rape specified the acts committed by each accused, such as tying the victim's hands and mouth, touching her private parts, and engaging in sexual intercourse against her will. During the commission of the crime, Don Juan Hidalgo was a minor.

The Regional Trial Court (RTC) found both accused guilty beyond reasonable doubt and imposed a death sentence on Roberto Hidalgo and reclusion perpetua on Don Juan Hidalgo for each count of rape. However, on appeal, the Court of Appeals affirmed the RTC's decision but modified the penalties. Roberto Hidalgo's death sentence was reduced to reclusion perpetua for each count of rape, while Don Juan Hidalgo's sentence was suspended in accordance with the Juvenile Justice and Welfare Act of 2006.

ISSUES:

  1. Whether the Court of Appeals erred in giving full faith and credence to the private complainant's testimony.

  2. Whether conspiracy was established and whether the accused-appellant is liable for three counts of simple rape.

  3. Whether there was a conspiracy between Roberto, Don Juan, and Bombasi in the commission of the crimes of rape.

  4. What penalty should be imposed on Roberto and Don Juan.

RULING:

  1. The appeal is dismissed for lack of merit. The Court of Appeals did not err in giving full faith and credence to the private complainant's testimony. Conspiracy was established and the accused-appellant is liable for three counts of simple rape.

  2. The Supreme Court held that there was a conspiracy between Roberto, Don Juan, and Bombasi in the commission of the crimes of rape. The acts committed by the accused demonstrated a concerted effort to rape the victim. Since there was conspiracy, the act of one of them was the act of all, and therefore, all three accused are equally guilty of all the crimes of rape committed against the victim.

  3. In the case of Roberto, the Supreme Court affirmed the imposition of reclusion perpetua for each of the crimes committed. Under Article 266-B of R.A. No. 8353, the penalty of reclusion perpetua to death shall be imposed whenever the crime of rape is committed by two or more persons. Since there were no aggravating or mitigating circumstances, the lesser penalty which is reclusion perpetua shall be imposed on Roberto.

  4. n the case of Don Juan, the Supreme Court found that he was a minor at the time of the commission of the crimes, and therefore, the Indeterminate Sentence Law (ISLAW) is applicable. The court held that the penalty to be imposed on Don Juan will be within the range of prision mayor from six (6) years and one (1) day to twelve (12) years, as minimum penalty to 14 years, eight (8) months and one (1) day to 17 years and four (4) months of prision temporal in its medium period, as maximum penalty in each of the three counts of rape. The court also applied the Juvenile Justice and Welfare Act of 2006, which mandates the suspension of the sentence of a child in conflict with the law, and ordered that Don Juan serve the period of his sentence in an agricultural camp and other training facilities.

PRINCIPLES:

  • In the prosecution of rape, the elements that must be proved are: (a) the accused had carnal knowledge of the victim; and (b) said act was accomplished through the use of force, threat or intimidation, depriving the victim of reason or consciousness, or when the victim is under 12 years old or is demented.

  • Conspiracy exists when the acts of the accused demonstrate a common design towards the accomplishment of the same unlawful purpose. Unity of action is shown through the collective acts of the accused.

  • Conspiracy exists when two or more persons come to an agreement concerning the commission of a felony and decide to commit it.

  • In a conspiracy, the act of one conspirator is the act of all.

  • The penalty for the crime of rape committed by two or more persons is reclusion perpetua to death, as provided under Article 266-B of R.A. No. 8353.

  • The Indeterminate Sentence Law (ISLAW) applies when the offender is a minor at the time of the commission of the crime.

  • The Juvenile Justice and Welfare Act of 2006 provides for the suspension of the sentence of a child in conflict with the law and the opportunity for restoration, rehabilitation, and reintegration into society.