GR 232192; (June, 2020) (Digest)
G.R. No. 232192 , June 22, 2020
Alejandro C. Miranda, Petitioner, vs. People of the Philippines, Respondent.
FACTS
An Information was filed charging Alejandro C. Miranda with rape through sexual assault under Article 266-A(2) of the Revised Penal Code, as amended. The charge alleged that on or about April 6, 2006, in Muntinlupa City, Miranda willfully inserted his penis into the anal orifice of AAA, a six-year-old boy. Upon arraignment, Miranda, assisted by counsel, pleaded not guilty. After trial, the Regional Trial Court convicted Miranda. The Court of Appeals affirmed the conviction with modifications to the damages awarded. Miranda filed a Petition for Review on Certiorari, assailing his conviction on the grounds that his warrantless arrest and detention were invalid, that he was deprived of his right to a preliminary investigation due to an inquest, and that Article 266-A of the Revised Penal Code is vague and ambiguous.
ISSUE
Whether or not petitioner Alejandro C. Miranda was properly convicted of rape through sexual assault.
RULING
The Petition is denied. The Supreme Court held that while Miranda’s warrantless arrest was not lawful under Rule 113, Section 5 of the Revised Rules of Criminal Procedure (as the barangay police were not present during the crime’s commission and acted only on information, not personal knowledge), and the subsequent inquest investigation was void (as an inquest is proper only after a lawful warrantless arrest), these irregularities do not negate his valid conviction. By pleading not guilty at arraignment without objecting to the legality of his arrest or the absence of a preliminary investigation, Miranda waived his right to question these defects and submitted to the jurisdiction of the trial court. Any irregularity in the arrest does not affect the court’s jurisdiction or the validity of a conviction duly proven beyond reasonable doubt. Furthermore, the Court found that Miranda was correctly convicted under Article 266-A(2) for committing an act of sexual assault by inserting his penis into the anal orifice of a child, a crime punishable in relation to Republic Act No. 7610 . The award of damages was modified in accordance with prevailing jurisprudence.