Case Digest (G.R. No. 261571)
Facts:
People of the Philippines v. Paul Joven y Senenche, G.R. No. 261571, May 29, 2024, Supreme Court Second Division, Leonen, SAJ., writing for the Court.
The People of the Philippines (plaintiff-appellee) prosecuted Paul Joven y Senenche (accused-appellant) on three Informations charging other sexual abuse under Article III, Section 5(b) of Republic Act No. 7610 for acts allegedly committed sometime between January and March 2016 against AAA, a then 17‑year‑old female with mild intellectual disability. On arraignment, Joven pleaded not guilty and trial on the merits followed.
At trial the prosecution presented AAA and her mother BBB; medico‑legal findings by Dr. Luna (admitted by the defense) showed healed hymenal lacerations and pregnancy. AAA testified that on two separate occasions between January and March 2016 Joven lured her to an abandoned building, forcibly laid her on a foam and had sexual intercourse with her against her will; she also stated that Joven threatened to throw stones at her house to compel her to meet him. BBB corroborated aspects of AAA’s condition and identification of Joven; AAA later reported the incidents to police and was examined, revealing pregnancy. The defense presented Joven as sole witness; he denied the acts, asserted an alibi that he was at work for a resort from February 13 to August 19, 2016 and claimed not to know AAA, though he admitted seeing her near her house when buying cigarettes.
The Regional Trial Court (RTC) convicted Joven of two counts of violation of Section 5(b), R.A. 7610 (other sexual abuse) and acquitted him of the third count, imposing prison terms and damages; it found AAA’s testimony credible and rejected denial and alibi defenses. Joven appealed to the Court of Appeals (CA).
In a June 3, 2021 Decision, the Court of Appeals affirmed with modification the RTC’s decision: it held that the facts showed sexual intercourse effected by force, intimidation and threats, and therefore the proper crime was rape under Article 266‑A, paragraph 1, in relation to Article 266‑B of the Revised Penal Code (RPC); it convicted Joven of two counts of rape and imposed reclusion perpetua for both counts (deleting the RTC’s fine). Joven filed a Notice of Appeal to the Supreme Court. T...(Pro-only)
Issues:
- Did the prosecution prove beyond reasonable doubt that accused‑appellant Paul Joven y Senenche committed two counts of rape under Article 266‑A(1) in relation to Article 266‑B of the Revised Penal Code?
- Was the crime here properly characterized as rape under Article 266‑A(1) rather than other sexual abuse under Section 5(b) of Republic Act No. 7610?
- What is the proper penalty and quantum of civil indemnity, moral and exemplary dama...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)