G.R. No. 261970 - People vs. Miranda y Parena

The case arose from an ordinary appeal under Rule 122 of the Rules of Court.
The accused, Dioni Miranda y PareAa (a.k.a. “Abe”), was initially convicted by the Regional Trial Court (RTC) for the crime of Statutory Rape under Article 266-A, paragraph (l)(d) of the Revised Penal Code (RPC).
The RTC found him guilty beyond reasonable doubt based on the testimony of the minor victim and corroborative evidence, and additionally noted the aggravating circumstance of ignominy, despite its non-allegation in the Information.
The Court of Appeals (CA) later affirmed the RTC’s decision with modifications—in particular, it ruled that Miranda was also guilty of Qualified Statutory Rape due to his relationship with the victim and increased the award for damages.

Miranda was charged for Qualified Statutory Rape, which under the Information alleged that on or about September 17, 2015 he committed the offense against a minor, AAA, who was seven (7) years old at that time.
The Information specified that the crime was committed with the presence of an aggravating circumstance of ignominy and alleged that the victim was the stepdaughter of the accused.
Miranda pleaded “not guilty” to the charges.

AAA first encountered Miranda at a terminal in Mabalacat, Pampanga.
Miranda took AAA to his shanty, where he subsequently became her “tatay-tatayan.”
During the time they lived together, Miranda repeatedly raped AAA.
On September 17, 2015, in a specific incident, he removed the victim’s clothing, inserted his penis into her vagina, and despite her shouts and pleas, continued the act.
After the act, Miranda ordered AAA to lie on a part of the shanty infested with ants and urinated on her.

Testimony of AAA, whose detailed and candid account was given during direct examination and cross-examination.
Medical findings from Dr. Elise V. Cruz, who observed physical evidence consistent with repeated sexual abuse.
Testimony of Rosalie Apolinario, a neighbor whose observations provided further confirmation by recounting how she encountered the aftermath of the assault.

He met AAA while collecting garbage and that she requested his help because she had no proper guardians.
He admitted to their living together for approximately five months before the filing of the case but denied any sexual abuse, attributing the child’s distress to a reprimand he gave her for unrelated behavior (watching television).

Found Miranda guilty beyond reasonable doubt of Statutory Rape.
Appreciated the aggravating circumstance of ignominy due to the degrading manner in which the crime was committed.
Imposed the penalty of reclusion perpetua without eligibility for parole and awarded civil indemnity, moral damages, and exemplary damages of P75,000.00 each.

Affirmed the RTC’s conviction with modifications, particularly by designating the crime as Qualified Statutory Rape under Article 266-A in relation to Article 266-B of the RPC.
Increased the award for damages to P100,000.00 each and reiterated the inclusion of the aggravating and qualifying circumstances.

The RTC failed to prove all elements of statutory rape beyond reasonable doubt.
The RTC improperly appreciated the aggravating circumstance of ignominy even though it was not alleged in the Information.

The Supreme Court, while upholding the conviction for Statutory Rape, found that the CA committed reversible error regarding the appreciation of the additional circumstances.

Upholding Miranda’s conviction for Statutory Rape when the prosecution proved the mandatory elements beyond reasonable doubt.
Appreciating the aggravating circumstance of ignominy, which was not alleged in the Information.
Recognizing the qualifying circumstance of the relationship (alleged stepfatherhood or guardianship) between Miranda and the victim, despite the evidence showing that Miranda was only the “tatay-tatayan” and not the legal guardian or stepfather.

Whether the imposition of enhanced penalties and increased damages based on these improperly appreciated circumstances was proper.