People v. Felipe Delos Santos

Summary

This Supreme Court En Banc Resolution modified a death sentence to reclusion perpetua in a rape case involving a step-father and his 13-year-old stepdaughter. The Court granted accused-appellant's motion to re-open, ruling that qualifying circumstances under RA 7659 must be properly pleaded in the Information. Since the step-father relationship was not alleged, it could not justify the death penalty. The Court applied the Garcia doctrine retroactively, emphasizing that qualifying circumstances are essential elements that must be specifically alleged in criminal informations. The decision demonstrates the strict procedural requirements in death penalty cases and the retroactive application of favorable criminal law interpretations. The accused was ordered to pay P50,000 compensatory damages and P50,000 moral damages to the victim.