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PEOPLE vs Mario Umayam

PEOPLE OF THE PHILIPPINES, appellee, vs. MARIO UMAYAM, appellant.

G.R. No. 147033 | 2003-04-30

D E C I S I O N

PANGANIBAN, J.:

In incestuous rapes, the age of the victim and her relationship with the offender must be both alleged in the information and proven beyond reasonable doubt during the trial; otherwise, the death penalty cannot be imposed. These circumstances alter the nature of the crime and increase the penalty.

The Case

For automatic review before this Court is the January 31, 2001 Decision[1] of the Regional Trial Court (RTC) of Ilagan, Isabela (Branch 16) in Criminal Case No. 2825, finding Mario Umayam guilty beyond reasonable doubt of qualified rape. The dispositive portion of the Decision reads thus:

"WHEREFORE,...