**Facts:**
1. **Initial Complaints:** On August 21, 1997, Catherine Linatoc, assisted by her mother, filed three criminal complaints against Eladio Viernes, the common-law husband of her mother, accusing him of rape and attempted rape.
2. **Charges:**
– **Criminal Case No. 0532-97:** Alleged rape on September 29, 1996.
– **Criminal Case No. 0533-97:** Alleged attempted rape in March 1997.
– **Criminal Case No. 0534-97:** Alleged rape on August 18, 1997.
3. **Investigation and Prosecution:** These complaints were filed before Prosecutor Danilo S. Sandoval and consolidated in the Regional Trial Court (RTC) of Lipa City, Branch 12. Viernes was arraigned and pleaded not guilty.
4. **Trial Court Decision (April 6, 1998):**
– **Conviction:** Found Viernes guilty of two counts of rape and one count of attempted rape.
– **Penalties:** Imposed penalties, including reclusion perpetua for each rape case and prision correccional for the attempted rape, alongside monetary damages.
5. **Prosecutor’s Motion for Reconsideration (May 18, 1998):**
– **Motion Filed:** Prosecutor Sandoval requested an increase in penalties to conform with Republic Act (RA) No. 7659.
– **RTC’s Order (May 21, 1998):** Increased the penalties, upgrading the sentences to death for the rape cases and reclusion temporal for the attempted rape case.
6. **Appeal:** Viernes appealed these decisions claiming wrongful convictions and excessive penalties.
**Issues:**
1. **Substantive Issues:**
– Whether the RTC erred in convicting Viernes of the crimes charged.
– Whether Viernes was properly identified and the necessary evidence for conviction was presented.
2. **Procedural Issue:**
– Whether the RTC erred in increasing the penalties via the Motion for Reconsideration, and whether this violated Viernes’ right against double jeopardy.
**Court’s Decision:**
1. **Rome v. Substantive Matters:**
– **Appellant’s Culpability:** The Supreme Court affirmed Viernes’ conviction. The testimonies of Catherine Linatoc were considered credible, being detailed and consistent. Her testimony was corroborated by physical evidence from the medico-legal officer showing laceration of the hymen.
– **Credibility:** The trial court’s assessment of Catherine’s testimony was upheld, reinforcing the belief that a young victim would not fabricate such a traumatic experience without basis.
– **Alibi Defense:** Viernes’ alibi and denial were weak and unsupported by credible evidence. His proximity to the crime scene removed the physical impossibility aspect of his defense.
2. **Rome v. Procedural Matters:**
– **Increase in Penalty:** The Supreme Court found the trial court’s act of increasing the penalties improper under the Rules of Court, particularly Section 7 of Rule 120, which allows modification of a judgment of conviction only upon the accused’s motion. The increase in penalties, therefore, violated Viernes’ right against double jeopardy.
3. **Final Disposition:**
– **Appeal Partially Granted:** The Supreme Court annulled the RTC’s Order increasing the penalties and reinstated the original decision with modifications in the award of damages:
– Moral damages were increased to P50,000 for each count of consummated rape.
– Exemplary damages were increased to P25,000 for each count of consummated rape.
**Doctrine:**
– **Modification of Judgment:** A judgment of conviction may be modified upon motion of the accused, not by the prosecution or the court unilaterally.
– **Double Jeopardy:** Instituting any motion or action that places the accused in double jeopardy is prohibited and considered a violation of procedural due process rights.
**Class Notes:**
– **Rape Conviction Elements:**
– Carnal knowledge of a woman.
– Done through force, threat, or intimidation, or when the victim is deprived of reason, unconscious, or under twelve years of age.
– **Attempted Rape:**
– Direct act leading towards the commission of rape.
– No completion due to reasons independent of the perpetrator’s will.
– **Credible Witness Testimony:** Consistency, spontaneity, and the absence of ill motive.
– **Legal Citations:**
– **Article 335, Revised Penal Code (as amended)**
– **Republic Act No. 7659** (Death Penalty Law)
– **Rule 130, Section 27, Rules of Court** (Offer of compromise as admission of guilt)
– **Rule 120, Section 7, Rules of Court** (Modification of judgment)
**Historical Background:**
– **Amendments to Criminal Penalties:** The case illustrates the transition in Philippine penal law particularly regarding the imposition of the death penalty and adjustments in juridical reviews of criminal cases over time.
– **Prosecutorial Procedures:** Highlights the importance of safeguarding procedural rights even post-conviction, emphasizing the court’s mandate to observe stringent due process.
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