Case Digest (G.R. No. 136300-02)
Facts:
People of the Philippines v. Emmanuel Aaron, G.R. Nos. 136300-02, September 24, 2002, Supreme Court Third Division, Corona, J., writing for the Court. The case arose from three separate criminal complaints, identically worded and sworn to on January 17, 1998, charging Emmanuel Aaron with three counts of rape under Articles 266-A and 266-B of the Revised Penal Code as amended by Republic Act No. 8353. The complaints alleged that on or about January 16, 1998 at Brgy. San Jose, Balanga, Bataan, Aaron, armed with a knife and by force and intimidation, had carnal knowledge of the offended party, Jona G. Grajo.On arraignment (January 30, 1998) Aaron, represented by counsel, pleaded not guilty to the three complaints and a joint trial ensued in the Regional Trial Court of Balanga, Bataan, Branch 3 (decision penned by Judge Lorenzo R. Silva, Jr.). The prosecution’s version was that at about 7:00 a.m. on January 16, 1998 Jona was asleep on a papag in her second-floor room, wearing only a panty and a blanket, when she awoke to find Aaron naked beside her; he allegedly mounted her, held a knife to her neck, covered her mouth, removed her panty, and had sexual intercourse with her three times while threatening her. Afterward she escaped wrapped only in a blanket, told neighbors and the landlady she had been raped, then reported the incident to the police. Police arrested Aaron at the house of a neighbor, Bong Talastas.
Medical examination by Dr. Emelita Firmacion produced a certificate noting multiple healed hymenal lacerations at 1, 3, 5, 6 and 9 o’clock positions; the doctor testified the lacerations were of the incomplete type and completely healed, which she said could indicate they had been sustained at least one month before the January 16, 1998 examination, though she conceded intercourse immediately before the exam was still possible.
Aaron testified in his defense that he had merely changed clothes upstairs, peeped through Jona’s partly open door, saw her in a panty, was met by her shouting, denied having a knife or committing rape, and contended she fabricated the charge out of embarrassment and spite. On October 14, 1998 the trial court found Aaron guilty of one count of rape and sentenced him to reclusion perpetua and ordered payment of P50,000 civil indemnity.
Aaron ap...(Subscriber-Only)
Issues:
- Did the trial court err in finding the accused guilty beyond reasonable doubt?
- Do the three acts of penetration described in the incident constitute three separate counts of rape or a single continuing act?
- Was the award of damages properly determined, and is additional mor...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
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Doctrine:
- (Subscriber-Only)