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People Vs Ramos G.R. No. 136398 November 23, 2000 Facts

Louie Ramos was charged with raping Eufemia Labrador at a birthday party. The trial court found Ramos guilty but considered mitigating circumstances and sentenced him to a lower penalty. The appellate court increased the penalty. The Supreme Court affirmed the appellate court's ruling, holding that under the Revised Penal Code, rape carries an indivisible penalty of reclusion perpetua regardless of mitigating circumstances. The Court also ordered Ramos to pay Labrador ₱50,000 in civil indemnity and ₱50,000 in moral damages, as required by current rules.

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146 views1 page

People Vs Ramos G.R. No. 136398 November 23, 2000 Facts

Louie Ramos was charged with raping Eufemia Labrador at a birthday party. The trial court found Ramos guilty but considered mitigating circumstances and sentenced him to a lower penalty. The appellate court increased the penalty. The Supreme Court affirmed the appellate court's ruling, holding that under the Revised Penal Code, rape carries an indivisible penalty of reclusion perpetua regardless of mitigating circumstances. The Court also ordered Ramos to pay Labrador ₱50,000 in civil indemnity and ₱50,000 in moral damages, as required by current rules.

Uploaded by

Margie Marj Galban
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© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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PEOPLE vs RAMOS

G.R. No. 136398 November 23, 2000

FACTS:
Accused-appellant Louie Ramos was charged with rape. Complainant Eufemia Labrador
(lesbian- 31 years old) testified that on November 6, 1995, she was at the house of accused-
appellant in Basobas Compound, Calapandayan, Subic, Zambales upon the invitation of
appellant’s sister, Mary Jane, to attend the birthday party of the latter’s laundrywoman, Linda.
The party was held in front of Linda’s house. Feeling drunk, Eufemia asked permission to leave
but Mary Jane prevailed upon her to sleep in her house that night. Mary Jane took Eufemia to her
house and made the latter sleep in her bedroom. The room had no partition but only had a red
curtain to separate it from the rest of the house. While Eufemia was asleep, she felt someone on
top of her and experienced some pain in her private parts, which was bleeding. Realizing that she
was being raped, Eufemia shouted and struggled to free herself, but the accused-appellant proved
to be too strong for her. Accused-appellant only stopped when they heard some noise outside the
room. Accused-appellant put on Eufemia’s short pants on her and hurriedly left, leaving his own
pants behind.

The Regional Trial Court considered two mitigating circumstances in favor of accused-appellant,
to wit: drunkenness and voluntary surrender. As there was no aggravating circumstance to offset
the mitigating circumstances. The RTC found Louie Ramos guilty of the crime rape and
sentenced him of prision mayor as minimum and reclusion temporal as maximum and awarding
the victim of moral and exemplary damages. However, The Court of Appeals increased the
penalty to reclusion perpetua and deleted the award of exemplary damages.

ISSUE:
Whether or not the appellate court erred in increasing the penalty.
HELD:
Under Art. 63 of the Revised Penal Code, since the crime of rape is punishable by reclusion
perpetua, a single indivisible penalty, the penalty should be applied by the trial court regardless
of any mitigating or aggravating circumstances that may have attended the commission of the
deed. Therefore, the penalty in the present case remains to be reclusion perpetua.

The current rule is that the complainant shall be awarded a civil indemnity of ₱50,000.00, with
an additional award of ₱50,000.00 as moral damages. This award is to be given even if there is
neither allegation nor evidence presented as basis therefor. The conventional requirement of
"allegata et probata" in civil procedure and for essentially civil cases is dispensed with in
prosecutions for rape with the civil aspect included therein since no appropriate pleadings may
be filed wherein such allegations can be made. The decision of the Court of Appeals is affirmed
with the modification that, in addition to the amount of ₱50,000.00 awarded as moral damages,
accused-appellant is ordered to pay complainant Eufemia Labrador the amount of ₱50,000.00 as
civil indemnity.

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