Case Digest (G.R. No. 203458)
Facts:
In People of the Philippines v. Quirino Balmes y Cleofe, G.R. No. 203458, June 06, 2016, the Supreme Court Third Division, Peralta, J., writing for the Court, resolved an appeal from a Court of Appeals decision affirming the conviction of appellant Quirino Balmes y Cleofe for three counts of rape committed against his daughter AAA.
On January 20, 2003, three separate Informations were filed charging Quirino with rape for acts alleged to have occurred in July 1992 (Crim. Case No. C-03-7163), September 1992 (Crim. Case No. C-03-7164), and May 23, 2002 (Crim. Case No. C-03-7165). Quirino pleaded not guilty at arraignment on May 14, 2003, and the three cases were tried jointly before the Regional Trial Court (RTC), Branch 40, Calapan City. The prosecution presented AAA, her brother BBB, her maternal aunt CCC, and Dr. Angelita C. Legaspi (the rural health physician who examined AAA). Quirino was the lone defense witness.
The RTC, after trial, found Quirino guilty beyond reasonable doubt of three counts of rape and, in a May 7, 2009 Joint Decision, sentenced him to three (3) reclusion perpetua and awarded Php100,000 civil indemnity, Php75,000 moral damages, and Php50,000 exemplary damages to AAA. The court emphasized AAA’s positive, clear and convincing testimony and rejected Quirino’s uncorroborated denial.
Quirino appealed to the Court of Appeals (CA). In its February 6, 2012 Decision in CA-G.R. CR-H.C. No. 04148 the CA affirmed the conviction but, adopting the Office of the Solicitor General’s recommendation, modified the penalties: it retained reclusion perpetua for each count but ruled Quirino not eligible for parole (citing R.A. No. 9346) and adjusted damages to P75,000 civil indemnity, P75,000 moral damages, and P30,000 exemplary damages per count.
Quirino then sought relief before...(Subscriber-Only)
Issues:
- Did the Court of Appeals err in affirming appellant Quirino Balmes’s conviction for three counts of rape?
- Were the penalty and damages imposed by the Court of Appeals proper, including the question of parole eligibility and the amounts of civil indemnity, moral and...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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