Case Digest (G.R. No. 232192)
Facts:
Alejandro C. Miranda v. People of the Philippines, G.R. No. 232192, June 22, 2020, Supreme Court Third Division, Leonen, J., writing for the Court.Petitioner Alejandro C. Miranda was charged by the City Prosecutor of Muntinlupa City by Information dated April 12, 2006, with rape through sexual assault for allegedly inserting his penis into the anal orifice of a six‑year‑old boy, hereinafter AAA, on April 6, 2006. Miranda pleaded not guilty at his arraignment on May 17, 2006, and the trial court granted his motion to reduce bail on May 22, 2006.
At trial before the Regional Trial Court (Branch 207, Muntinlupa City), the victim testified that Miranda pulled him into Miranda’s house, undressed him, and inserted his penis into the child’s anus, causing pain; the victim reported the incident to his stepfather BBB, and barangay police subsequently invited Miranda to the barangay hall, where he voluntarily went and was detained after identification. Miranda denied the accusation, claiming a close personal relationship with the victim and his family.
On February 12, 2010, the RTC found Miranda guilty beyond reasonable doubt of sexual assault under the second paragraph of Article 266‑A of the Revised Penal Code (rape through sexual assault) and imposed an indeterminate sentence and damages. Miranda appealed to the Court of Appeals, which, in a July 30, 2014 Decision, affirmed conviction but increased the civil and moral damages and awarded legal interest. The CA denied reconsideration (initially for failure to comply with the Efficient Use of Paper rule, later admitting a compliance filing but denying the motion on the merits by April 26, 2017 Resolution).
Miranda filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court seeking reversal of the CA judgment, principally arguing (1) his warrantless arrest and consequent inquest deprived him of a ...(Pro-only)
Issues:
- Did petitioner waive or lose the right to challenge the lawfulness of his warrantless arrest or the absence of a preliminary investigation by pleading not guilty at arraignment, and was his warrantless arrest lawful under Rule 113, Section 5 of the Rules of Court?
- Is Article 266‑A(2) of the Revised Penal Code vague or constitutionally infirm as petitioner contends?
- Was petitioner properly convicted of rape through sexual assault under Article 266‑A(2) (as amended) in relation to Republic Act No. 7610, and...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)