People vs. Sultan Case Digest
People vs. Sultan Case Digest
People vs. Sultan Case Digest
Facts:
One evening on June 2, 1997, Juditha M. Bautista, the victim, was on her way home when she was accosted
in a dark alley by the accused, Fernando Sultan, who pointed a sharp object at her neck and told her this is a hold-up.
He managed to drag her into his house and started robbing her watch, earrings, ring, necklace and her Php 130 cash.
He then started sexually abusing her; this sexual abuse happened twice in a span of less than an hour. After sexually
accosting the victim, he promised her that he would answer for everything that he had done to her and asked her to
elope with him in which the victim agreed in an effort to finally be freed. When the accused allowed her to go back
to her house to get her things for their planned elopement, she managed to ask for help from the police. The accused
was then arrested. The trial court charged him for a special complex of robbery with rape.
Issue:
Whether or not the rape that was committed twice by the accused to the victim should be considered as
aggravating circumstances.
Held:
The additional rapes that was committed by the accused should not be considered as aggravating
circumstances. The Court observed that there was no law providing for the additional rape/s or homicide/s considering
them as aggravating circumstances. Furthermore, Article 14 of the Revised Penal Code, Aggravating Circumstances,
is an exclusive list which means that unless and until a law is passed regarding the additional rape/s as an aggravating
circumstance, the Court must construe in favor of the offender. Therefore, the accused was rightfully charged with a
special complex of robbery with rape with neither mitigating nor aggravating circumstances.