Case Digest (G.R. No. 262846) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
This case involves the appeal of People of the Philippines v. XXX262846, G.R. No. 262846, decided en banc on February 18, 2025 under the 1987 Philippine Constitution. Two Informations were filed before the Regional Trial Court (RTC), Branch 26, Medina, Misamis Oriental. In F.C. Crim. Case No. 065-M (2013), the accused-appellant, XXX262846, was charged with rape under Article 266-A(1) of the Revised Penal Code, as amended by R.A. 8353, for allegedly having forceful carnal knowledge of his 16-year-old daughter, AAA262846, sometime in the first week of January 2013 at xxxxxxxxxxx, xxxxxxxx, xxxxxxxxxxxxxx. In F.C. Crim. Case No. 066-M (2013), he was charged with attempted rape under Article 266-A in relation to Articles 6 and 51 of the RPC for overt acts in the last week of January 2013 that commenced rape but did not consummate due to the victim’s resistance.AAA262846 testified that on the first occasion her father kicked her awake at about 11:00 p.m., pulled her hair, covered
Case Digest (G.R. No. 262846) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background
- Accused-appellant XXX262846 (father) charged under two Informations before RTC Branch 26, Medina, Misamis Oriental:
- F.C. Crim. Case No. 065-M (2013) for rape under Article 266-A(1) in relation to Article 266-B of the RPC, amended by RA 8353.
- F.C. Crim. Case No. 066-M (2013) for attempted rape under Articles 266-A, 266-B, 6 and 51 of the RPC.
- Victim AAA262846, then 16-year-old daughter and first-year college student, lived with accused; mother was overseas worker.
- First Incident (First Week, January 2013)
- Around 11:00 p.m., AAA262846 asleep when accused kicked her, pulled her hair, covered her mouth, pulled down her shorts and underwear, touched her breasts, and inserted his penis into her vagina.
- AAA262846 could not cry out; accused threatened to kill her family if she resisted; he then left to sleep.
- Second Incident (Last Week, January 2013)
- At midnight, AAA262846 found her shorts removed and accused exposing himself, preparing to mount her.
- She bent her knee, hit his stomach, causing him to desist; accused threatened her support and freedom.
- Disclosure and Evidence
- AAA262846 confided in friends and brother when accused left for work on February 10, 2013; they reported to police and grandmother.
- Medical exam (Feb. 12, 2013) by Dr. Analiza B. Bajan: healed complete hymenal laceration at 7 o’clock; healed partial lacerations at 1, 5, 11 o’clock—penetration confirmed.
- Defense and Alibi
- Accused denied and claimed he was in Cagayan de Oro boarding house throughout January 2013.
- Witnesses YYY262846 and ZZZ262846 testified to his alleged continuous absence from family home.
- Lower Courts’ Decisions
- RTC (June 26, 2018):
- Convicted rape—reclusion perpetua + PHP 100,000 civil indemnity, moral and exemplary damages each.
- Downgraded attempted rape to unjust vexation—30 days arresto menor + PHP 10,000 civil indemnity.
- CA (Jan. 26, 2021): Affirmed RTC decision in all respects.
- Supreme Court appeal filed by accused.
Issues:
- Whether the Court of Appeals erred in affirming XXX262846’s conviction for rape under Article 266-A(1) of the RPC.
- Whether the CA erred in affirming the conviction for unjust vexation instead of attempted rape under Article 266-A(1) and related provisions.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)