People v. Renato Dadulla y Capanas

Summary

Father Renato Dadulla was prosecuted for raping and attempting to rape his daughter AAA in January 1998. The RTC initially imposed death penalty for rape and convicted him of attempted rape. The Court of Appeals modified the conviction to simple rape with reclusion perpetua (due to failure to allege relationship in information) and acts of lasciviousness (finding insufficient evidence of intent to have carnal knowledge). The Supreme Court affirmed these convictions but added exemplary damages, ruling that relationship as an aggravating circumstance, though not alleged in the information and thus not affecting criminal liability, still entitled the victim to exemplary damages under civil law. This case demonstrates the strict procedural requirements for qualifying circumstances in criminal informations and the distinction between criminal and civil liability regarding aggravating circumstances.