Search

Title
People v. Olpindo y Reyes

Case Ponente Decision Date

G.R. No. 252861 GESMUNDO, C.J : 2022-02-15

Case AI Summary AI Digest Ask Jurist AI

Facts
This case involves an appeal from the decision of the Court of Appeals (CA) affirming the conviction of
Alexander Olpindo y Reyes (accused-appellant) for the crime of rape. The case originated from the Regional
Trial Court (RTC) of San Jose City, Branch 38, where accused-appellant was found guilty of rape and
sentenced to reclusion perpetua.

On February 27, 2008, the accused-appellant, together with his sister, forced the victim, a 14-year-old
minor, into a tricycle and brought her to an uninhabited place. The accused-appellant then raped the victim
against her will. The victim reported the incident to her aunt the following day. The accused-appellant was
eventually apprehended on December 4, 2012, after evading arrest.

During the trial, the prosecution presented the testimony of the victim, as well as a medical report prepared
by Dr. Janine Duran, who examined the victim. The defense, on the other hand, presented the testimony of
the accused-appellant and a witness who claimed to know about the relationship between the accused-
appellant and the victim.

The RTC found the accused-appellant guilty of rape, considering the evidence presented by the
prosecution and the flight of the accused-appellant before his arrest. The RTC sentenced the accused-
appellant to reclusion perpetua and ordered him to pay damages to the victim.

On appeal, the CA affirmed the decision of the RTC, giving credence to the testimony of the victim and the
medical findings. The CA also noted that the damages awarded should be increased but did not modify the
damages due to the finality of the RTC decision.

Issue
The main issue raised in this case is whether the appeal by certiorari is the proper remedy in criminal cases
where the penalty imposed is either reclusion perpetua or life imprisonment.

Ruling
The Court dismissed the appeal, finding no reversible error in the CA's decision. The Court explained that
the case was not subject to automatic review, as the rule on automatic review of death penalty cases was
rendered ineffective by the enactment of Republic Act No. 9346, which prohibited the imposition of the
death penalty. The Court also clarified that the RTC's decision, which imposed the penalty of reclusion
perpetua, had already become final and executory after the accused-appellant failed to file a notice of
appeal. Nonetheless, the CA still reviewed the case to minimize the possibility of errors of judgment.

In affirming the conviction, the Court found that the prosecution had sufficiently proven all the elements of
:
 rape, and the testimony of the victim, coupled with the medical findings, was credible. The Court also
rejected the accused-appellant's defense of denial and alibi, noting that the positive identification of the
victim prevailed.

Ratio
The Court clarified that appeal by certiorari is the proper remedy in criminal cases where the penalty
imposed is either reclusion perpetua or life imprisonment. The Rules of Court provide that a review of
appeals filed before the Supreme Court is not a matter of right, but of sound judicial discretion. Only
questions of law should be raised in petitions filed under Rule 45, as factual questions are not the proper
subject of an appeal by certiorari.

The Court also discussed the confusion caused by the pronouncement in the case of People v. Mateo,
wherein it was stated that cases where the penalty imposed is reclusion perpetua or life imprisonment are
subject to the mandatory review of the Supreme Court. However, the Court clarified in the case of People v.
Rocha that this was not the intention of the Mateo ruling. The Court explained that prior to Mateo, the
Supreme Court had jurisdiction to directly review reclusion perpetua, life imprisonment, and death penalty
cases. The mode of review, however, was different. Reclusion perpetua and life imprisonment cases were
brought before the Supreme Court via a notice of appeal, while death penalty cases were reviewed by the
Supreme Court on automatic review.

To address the confusion, the Court issued A.M. No. 00-5-03-SC, which amended the Rules of Court to
provide for the proper modes of appeal in criminal cases. Under the amended rules, in cases where the
penalty imposed by the RTC is reclusion perpetua or life imprisonment, an appeal is taken by filing a notice
of appeal with the RTC. On the other hand, in cases where the penalty imposed by the RTC is death, the
Court of Appeals (CA) shall automatically review the same without the need for a notice of appeal.

However, on June 24, 2006, Republic Act No. 9346 was enacted, prohibiting the imposition of the death
penalty. As a result, trial courts are now precluded from imposing the penalty of death and instead shall
impose either reclusion perpetua or life imprisonment, depending on the nomenclature of penalties used by
the law violated. Consequently, the provisions of the Rules of Court which prescribe an automatic review by
the CA of cases where the death penalty is imposed became ineffective.

Summary
The Court dismissed the appeal and affirmed the conviction of the accused-appellant for the crime of rape.
The decision of the CA, which affirmed the decision of the RTC, was upheld. The Court clarified that appeal
by certiorari is the proper remedy in criminal cases where the penalty imposed is either reclusion perpetua
or life imprisonment. The Court also discussed the confusion caused by previous rulings and the
amendments to the Rules of Court regarding the modes of appeal in criminal cases. The Court emphasized
the importance of adhering to procedural rules but also recognized the need to serve the broader interests
of justice.

Privacy Policy Terms of Service

© 2023 Jurist AI. All rights reserved.

:
: