Case Summary (G.R. No. 167179)
Applicable Law
The legal basis for the charges arises from the Revised Penal Code, specifically Article 266(A) and (B), as amended by Republic Act (R.A.) No. 8353 and R.A. No. 7659. Furthermore, a central element of the case is the repeal of the Death Penalty Law through R.A. No. 9346, which impacts the sentencing options available for the convicted individual.
Charges and Plea
Elmer Ceredon y Pagaran faced ten counts of rape, all committed against his sister when she was a minor. During the trial, he initially pleaded not guilty, but later, during a pretrial conference, he opted to change his plea to guilty on all counts. The court granted this request, and a joint trial followed, where the prosecution presented witness testimonies without any evidence from the defense.
Facts of the Case
The chronology of incidents spans from 1995 to 2000, during which the accused repeatedly raped AAA, who was between the ages of 10 to 15 during these offenses. The occurrences involved threats of violence, physical coercion, and extreme psychological intimidation, effectively silencing the victim through fear.
Trial Court and Court of Appeals Proceedings
The trial court found Ceredon guilty of all ten counts of rape, initially imposing the death penalty before the case was escalated to the Court of Appeals (CA). The CA affirmed the trial court's decision but modified the sentence from death to reclusion perpetua, following the precedent set by the repeal of the Death Penalty Law.
Issues Raised on Appeal
Ceredon contested his conviction on several grounds:
- He claimed his plea of guilty was improvident due to lack of thorough inquiry by the trial court into his understanding of the consequences.
- He argued that the Informations filed against him failed to sufficiently establish the exact dates of the offenses.
- He contended the court erred in imposing the death penalty for one count based on insufficient establishment of qualifying circumstances regarding his familial relationship with the victim.
Court's Ruling on Issues
The Supreme Court ruled against the appellant's claims:
- The court held that there was no improvident plea of guilty as Ceredon was adequately informed of the charges and consequences, particularly since his conviction was also based on overwhelming evidence presented by the prosecution.
- The determination of exact dates was deemed non-essential; the charges were sufficiently clear about the nature of the offenses, and the timeline was plausible given the psychological trauma experienced by the victim.
- The court clarified the indictment's language sufficed in denoting the relationship as sufficient for establishing the qualifying circumstance necessary for a rape conviction.
Sentenci
...continue readingCase Syllabus (G.R. No. 167179)
Overview of the Case
- The case involves Elmer Ceredon y Pagarang, accused of committing ten counts of incestuous rape against his youngest sister, referred to as AAA.
- The crimes were committed in Cagayan between 1995 and 2000, with the victim being a minor at the time of the offenses.
- The appellant was sentenced to reclusion perpetua following the repeal of the death penalty in the Philippines.
Nature of the Crimes
- The court describes incestuous rape as one of the most heinous crimes, evoking public outrage and condemnation.
- The repeal of the Death Penalty Law through R.A. No. 9346 resulted in the appellant facing reclusion perpetua for his actions against a minor.
Charges and Arraignment
- The appellant was charged with ten counts of rape under Article 266(A) and (B) of the Revised Penal Code.
- During his arraignment on August 13, 2001, he initially pleaded not guilty but later changed his plea to guilty on September 3, 2001.
- A joint trial followed, primarily involving testimonies from AAA and her teacher, with no defense evidence presented.
Detailed Account of the Incidents
- Criminal Case No. 08-1296: The first rape occurred in 1995 when AAA was ten years old. Appellant threatened her with a knife and used force to commit the act.
- Criminal Case No. 08-1297: The second incident involved similar threats and occurred later that same year.
- Criminal Case No. 08-1298: The third rape took place while AAA was sleeping, with the appellant again using intimidation.
- Criminal Case No. 08-1299: This incident followed shortly after the third, with AAA once again coerced at knife-point.
- Criminal Case No. 08-1300: The fifth rape occurred during the day after AAA returned home from visiting their grandfather.
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