Case Digest (G.R. No. 223099)
Facts:
- Charges: Lino Alejandro y Pimentel faced two counts of rape under Article 266-A, paragraph 1 (a) of the Revised Penal Code, in relation to Republic Act No. 8369.
- Victim: AAA, a 12-year-old minor, claimed Alejandro raped her twice in Cauayan City, Isabela.
- First Incident: Alejandro followed AAA, grabbed her, took her to a secluded area, and raped her.
- Second Incident: Alejandro entered AAA's house through a window and raped her again.
- Disclosure: AAA told her mother, BBB, who then took her to the Municipal Health Office.
- Medical Examination: Dr. CCC found hymenal lacerations on AAA, indicating sexual intercourse.
- Initial Acquittal: The RTC of Cauayan City, Isabela, Branch 20, acquitted Alejandro on July 26, 2011.
- Recall of Acquittal: Later the same day, the RTC recalled the acquittal after an error involving misfiled orders was identified by Assistant Provincial Prosecutor Roderick Cruz.
- Conviction: The RTC found Alejandro guilty on both counts, sentenced him to reclusion perpetua for each, and ordered him to pay damages.
- Appeal: Alejandro appealed to the CA, arguing the RTC erred in recalling the acquittal and failed to prove his guilt beyond reasonable doubt.
- CA Decision: The CA dismissed the appeal, affirmed the RTC's decision, and modified the damages to include legal interest.
Issue:
- (Unlock)
Ruling:
- Double Jeopardy: Yes, the RTC erred in recalling its initial decision acquitting the accused-appellant, thereby violating his right against double jeopardy.
- Justification of Conviction: The conviction of...(Unlock)
Ratio:
- Finality-of-Acquittal Doctrine: The Supreme Court emphasized that an acquittal is final, unappealable, and immediately executory upon promulgation.
- Constitutional Guarantee: The 1987 Constitution ensures the right against double jeopardy.
- Double Jeopardy Elements: These elements include valid information, a court of competent jurisdiction, the accused's arraignment and plea, and a judgment of acquittal or dismissal without the accused's consent.
- Case Context: All elements were met, and the acquittal was rendered and promulgated on July 25, 2011.
- Exceptions to Double Jeopardy: Exceptions include deprivation of due process or grave abuse of discretion, which did not apply in this case.
- Prosecution's Opportunity: The prosecution had its chance to present the case, and the acquittal was not questioned based on grave abuse of discretion.
- Improper Recall: The RTC's recall of the acquittal without a petition for certiorari under Rule 65 was improper.
- Supporting Precedents: The Supreme Court cited cases like "People v. L...continue reading
Case Digest (G.R. No. 223099)
Facts:
In the case of "People vs. Alejandro y Pimentel," Lino Alejandro y Pimentel was charged with two counts of rape under Article 266-A, paragraph 1 (a) of the Revised Penal Code, in relation to Republic Act No. 8369. The victim was a 12-year-old minor, referred to as AAA. The incidents occurred in Cauayan City, Isabela. On the first occasion, Alejandro allegedly followed AAA, grabbed her, took her to a secluded area, and raped her by inserting his penis into her vagina. On another occasion, Alejandro reportedly entered AAA's house through a window and raped her again. AAA disclosed the incidents to her mother, BBB, who then took her to the Municipal Health Office for examination. Dr. CCC, who conducted the examination, found lacerations in AAA's hymen, indicating sexual intercourse.
Initially, the Regional Trial Court (RTC) of Cauayan City, Isabela, Branch 20, acquitted Alejandro on July 26, 2011. However, on the same day, the RTC recalled the acquittal after Assistant Provincial Prosecutor Roderick Cruz pointed out that orders mistakenly placed in the records of a different case involving the same accused but a different victim. The RTC issued an order to rectify the error and subsequently found Alejandro guilty of two counts of rape. He was sentenced to reclusion perpetua for each count and ordered to pay damages.
Alejandro appealed to the Court of Appeals (CA), arguing that the RTC erred in recalling the acquittal and convicting him despite the prosecution's failure to prove his guilt beyond reasonable doubt. The CA dismissed the appeal and affirmed ...