PEOPLE v.

ECHEGARAY
GR NO. 117472
FEBRUARY 01, 1997
FACTS:
On June 25, 1996, Supreme court rendered a decision affirming the conviction of Echegaray for raping
his 10-year-old daughter, imposing R.A. 7659 or the Death Penalty Law which was already in effect at
the time of the commission of the crim in 1994. On July 9, 1996, Accused filed a Motion for
Reconsideration, saying he was falsely accused because of sinister motives of the victims
grandmother. On August 6, 1996, Echegaray discharged his counsel Atty. Vitug but retained services
of the Free Legal Assistance Group (FLAG).
On August 23, 1996, SC received a Motion which asked for the reversal of death sentence.
ISSUES: Whether RA 7659 is constitutional?
HELD:
Yes. The death penalty is not a cruel and unjust punishment. Jurisprudence provides that punishments
are cruel and unjust when they involve torture or a lingering death. As long as our law provides for its
imposition in certain cases, the courts must impose it.
RA 7659 meets all the requirements for the reimposition of the death penalty. The defendant says that
the death penalty is unconstitutional for (1) having been enacted in the absence of compelling reason
therefor and (2) death penalty for rape is cruel and excessive. The constitutional exercise of the limited
power to re-impose the death penalty entails: (1) that Congress define or describe what is meant by
heinous crimes; (2) that Congress specify and penalize by death, only crimes that qualify as heinous in
accordance with the definition of decription set in the death penalty bill; (3) that Congress, in enacting
this death penalty bill be singularly motivated by compelling reasons involving heinous crimes.
The assailed law provides the crimes punishable by death under this Act are heinous for being
grievous, odious, and hateful offenses and which, by reason of their inherent or manifest wickedness,
viciousness, atrocity, and perversity are repugnant and outrageous to the common standards and
norms of decency and morality in a just civilized and ordered society. The SC finds this a sufficient
definition of heinous crimes.
SC does not agree that the gauge of whether or not a crime warrants the death penalty or not is the
attendance of the circumstances of death on the part of the victim. The SC has no doubts as to the
innate heinousness of the crime of rape, as held in the case of People v. Cristobal.
Two types of crimes punished by death penalty: (1) those which are punished by RP to death; (2) those
with mandatory capital punishment with the presence of certain qualifying circumstances.

Prepared by: Liz Angela A. Intia