People v. Sandoval

Summary

Noel Sandoval was charged with seven counts of rape against his minor step-daughters Teresa (13) and Victoria 'Rhea' Micu (11). The Regional Trial Court convicted him of six counts and imposed the death penalty. On automatic review, the Supreme Court affirmed the conviction but reduced the penalty to reclusion perpetua. The Court held that while the prosecution proved the rapes beyond reasonable doubt, the death penalty could not be imposed because the qualifying circumstances of minority and relationship were not properly alleged in the original informations. Substantial amendments after arraignment would violate due process. The decision establishes that qualifying circumstances in rape cases must be both alleged and proved to warrant the death penalty. The Court awarded civil indemnity, moral damages, and exemplary damages totaling P660,000.