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PEOPLE v. ALEX DE LOS SANTOS Y SANTOS

This case has been cited 3 times or more.

	GR Nos. 140034-35 2003-08-14	PEOPLE v. RODOLFO ZABALA Y BACORRO QUISUMBING, J.
As to damages, the trial court awarded moral damages but failed to award civil indemnity. Moral damages are separate and distinct from civil indemnity awarded to rape victims. Civil indemnity, which is actually in the nature of actual or compensatory damages, is mandatory upon the finding of the fact of rape.[32] Thus, civil indemnity in the amount of P50,000.00 should be awarded here for each count of rape, in line with recent case law,[33] together with another sum of P50,000.00 as moral damages, without need for pleading or proof of the basis thereof.[34]
	GR No. 117691 2000-03-01	PEOPLE v. EDUARDO SAMPIOR Y BERICO QUISUMBING, J.
We note, however, that the trial court awarded neither civil indemnity nor moral damages to the offended party. Pursuant to current jurisprudence, the private complainant is entitled to civil indemnity of P50,000.00 for each count of rape.[23] An additional P50,000.00 as moral damages should likewise be granted for each count of rape,[24] without need of further proof. To serve as deterrent against sexual abuse of young women by their fathers, exemplary damages in the amount of P25,000.00 should also be imposed for each count of rape.[25]
	GR No. 125341 2000-02-09	PEOPLE v. JOEY BARCELONA Y SADILLE MENDOZA, J.
The trial court granted only P50,000.00 as moral damages in favor of complainant. Moral damages is separate and distinct from the civil indemnity awarded to rape victims.[39] In accordance with our recent rulings, an award of P50,000.00 should be given to complainant as her civil indemnity, in addition to the P50,000.00 moral damages awarded by the trial court.[40]