Allegation of Aggravating Circumstance / Exemplary Damages

The failure of the prosecution to allege in the information AAA’s relationship to appellant will not bar the consideration of the said circumstance in the determination of his civil liability. In any case, even without the attendance of aggravating circumstances, exemplary damages may still be awarded where the circumstances of the case show the “highly reprehensible or outrageous conduct of the offender (People v. Laog, G.R. No. 178321, October 5, 2011)