People of the Philippines vs.

Quiachon
CASE DIGEST: G.R. No. 170236, August 31, 2006
Criminal Law, Penalties, Rap

FACTS:

Appellant Roberto Quiachon was charged with the crime of qualified rape committed against her
eight-year-old deaf-mute daughter in 2001. Key witnesses for the prosecution were the victim
and her 11-year-old brother; for the defense, it was appellants mere bare denial. The victims
testimony was supported by medico-legal findings indicating rape. The trial court found the
appellant guilty and sentenced him to death plus payment of damages. On automatic appeal,
the Court of Appeals affirmed the decision and also imposed civil indemnity. Notably, Republic
Act 9346 was enacted on June 24, 2006 prohibiting the imposition of the death penalty.

ISSUES:

1.) Whether or not appellant is guilty of rape based on the evidence presented?
2.) Whether or not death was still the proper penalty imposed in view of RA 9346, considering
that the crime was committed before the laws enactment?
3.) That in case death penalty is reduced to reclusion perpetua, is civil indemnity still proper?

HELD:

On the first issue, the Court finds the accused guilty. In rape cases, the credibility of
complainant's testimony is the primordial consideration in determining if accused is guilty, and
the trial court is in a better position to determine such, having the full opportunity to observe
directly the witnesses' behavior. The victims testimony was "simple, straightforward, unshaken
by a rigid cross-examination, and unflawed by inconsistency or contradiction." It was further
corroborated by the medico-legal report. From this damning evidence, appellant's simple denial
of the charge against him must fail.

On the second issue, reclusion perpetua, not death penalty, is the proper penalty in this case in
view of RA 9346. Although the crime was committed before the law was enacted,favorabilia
sunt amplianda adiosa restrigenda, or penal laws which are favorable to accused are given
retroactive effect. (Article 22, Revised Penal Code) But appellant is not eligible for parole
because Section 3 of RA 9346 provides that "persons convicted of offenses punished with
reclusion perpetua, or whose sentences will be reduced to reclusion perpetua by reason of the
law, shall not be eligible for parole."

On the third issue, even if the penalty of death is not to be imposed because of the prohibition in
RA 9346, civil indemnity is still proper because it is not dependent on the actual imposition of
the death penalty but on the fact that qualifying circumstances warranting the imposition of the
death penalty attended the commission of the offense. The award of civil indemnity shows "not
only a reaction to the apathetic societal perception of the penal law and the financial fluctuations
over time but also the expression of the displeasure of the court of the incidence of heinous
crimes against chastity."