Case Summary (G.R. No. 170287)
Key Dates
October 24, 1996 – Alleged commission of rape
January 24, 1997 – Filing of the Information for rape
March 5, 1997 – Arraignment; appellant pleads not guilty
April 14, 1998 – RTC Decision convicting and imposing death penalty
September 27, 2002– Supreme Court Decision
Applicable Law
– 1987 Philippine Constitution (due process, right to be informed of the nature and cause of accusation)
– Revised Penal Code, Article 335, as amended by Section 11 of Republic Act No. 7659 (Death Penalty Law) and by Republic Act No. 8353 (Anti-Rape Law of 1997)
Facts of the Case
During a family reunion on appellant’s birthday, the then–sixteen-year-old victim was summoned by her parents from the family house to a farm hut about one kilometer away. In the hut, appellant embraced, kissed, undressed, threatened and twice had sexual intercourse with his daughter over a four-hour period against her will. Three days later, the victim filed a complaint and submitted to a medical examination, which disclosed hymenal rupture and vaginal abrasion consistent with recent sexual abuse. She testified to a prior incident at age thirteen, although no complaint was then filed. Appellant later sent two letters to his daughter, one expressly admitting the rape.
Trial Court Ruling
The RTC credited the victim’s straightforward testimony, the medico-legal findings and appellant’s letters of admission. Finding guilt beyond reasonable doubt for qualified rape (victim under eighteen and offender a parent), the court imposed the death penalty under Article 335 (as amended) and ordered indemnity of ₱50,000.
Issues on Appeal
- Whether the prosecution established guilt beyond reasonable doubt (sufficiency of evidence).
- Whether the imposition of the death penalty violated appellant’s right to be properly informed of the qualified nature of the offense.
Supreme Court Ruling: Sufficiency of Evidence
Upon automatic de novo review, the Court found the victim’s detailed testimony and appellant’s own admission conclusive proof of rape beyond reasonable doubt. The appeal did not challenge liability, and no reason existed to disturb the conviction.
Supreme Court Ruling: Proper Penalty
The Court held that qualifying circu
Case Syllabus (G.R. No. 170287)
Procedural Posture
- This case is before the Supreme Court on automatic review pursuant to the imposition of the death penalty by the Regional Trial Court (RTC) of San Jose, Occidental Mindoro, Branch 46, in Criminal Case No. R-4114.
- On April 14, 1998, the RTC convicted appellant Delfin dela Cruz of rape under Article 335 RPC and Section 11 of R.A. 7659 and sentenced him to death, ordered civil indemnity of ₱50,000, and directed his transfer to New Bilibid Prison.
- Appellant pleaded not guilty at arraignment on March 5, 1997. He did not challenge guilt on appeal but questioned the imposition of the death penalty for lack of proper notice of qualifying circumstances in the Information.
- The Supreme Court conducted a de novo review of the entire record, as required in criminal cases imposing capital punishment.
Facts of the Case
- Victim: Private complainant Marikit dela Cruz, then sixteen (16) years old and the seventh child of appellant.
- Date and place of alleged crime: October 24, 1996, around midnight, in a nipa hut one kilometer from the family home in Barangay Lagnas, Sablayan, Occidental Mindoro.
- Occasion: Family reunion and appellant’s birthday celebration at the farm, ending past 9:00 PM.
Version of the Prosecution
- Marikit was summoned by her mother to meet her father at the water pump “bombaa” near their house.
- Appellant invited Marikit to the farm hut despite her initial refusal due to cold and fear; her mother urged her compliance.
- Inside the hut, appellant:
- Embraced, kissed, and undressed Marikit by force and intimidation.
- Threatened her with harm when she resisted.
- Had carnal knowledge of her private parts twice over a four-hour period.
- Marikit cried, asked why her father raped her, and appellant remained silent.
- Three days later, October 28, 1996, Marikit filed a complaint and underwent medico-legal examination revealing:
- Hymen not intact.
- Abrasion on the p