Case Digest (G.R. No. 219615)
Facts:
- The case involves the People of the Philippines as the plaintiff-appellee against Rafael Agudo y Del Valle, the accused-appellant, in a qualified rape case.
- Events occurred in Barangay Simminublan, Municipality of San Narciso, Province of Zambales, Philippines, between 2005 and September 11, 2008.
- The accused-appellant was charged with raping his daughter, referred to as AAA, born on May 18, 1992.
- The family lived in a small hut with a makeshift curtain as a door, lacking adequate privacy.
- The first incident of sexual abuse occurred in 2005 when AAA was 13 years old; the accused entered the hut while she was asleep, threatened her, and sexually assaulted her.
- This pattern of abuse continued over the years, with multiple incidents, including specific occurrences on September 11 and September 15, 2008.
- After the latter incident, AAA confided in her mother and aunt, leading to a report to local authorities.
- The Regional Trial Court (RTC) found AAA's testimony credible and consistent with medical findings indicating she was no longer a virgin and had shallow healed lacerations.
- On May 2, 2013, the RTC convicted Rafael Agudo y Del Valle of qualified rape, sentencing him to reclusion perpetua and ordering him to pay damages.
- The Court of Appeals (CA) affirmed this decision on October 24, 2014, leading to the present appeal.
Issue:
- (Unlock)
Ruling:
- The Supreme Court affirmed the conviction of Rafael Agudo y Del Valle for qualified rape, upholding the decisions of both the RTC and the CA.
- The Court modified the damages awarded, increas...(Unlock)
Ratio:
- The Supreme Court found that the prosecution established the elements of qualified rape as defined under Article 266-A of the Revised Penal Code.
- The first element, carnal knowledge, was corroborated by AAA's credible testimony, supported by her mother and aunt's testimonies, and the medico-legal report indicating physical evidence of sexual abuse.
- The second element, that the act was accomplished through force, threat, or intimidation, was established through AAA's testimony about her father's threats.
- The Court emphasized that a parent's moral ascendancy over a child suffices to establish...continue reading
Case Digest (G.R. No. 219615)
Facts:
The case involves the People of the Philippines as the plaintiff-appellee against Rafael Agudo y Del Valle, the accused-appellant, in a qualified rape case. The events transpired in Barangay Simminublan, Municipality of San Narciso, Province of Zambales, Philippines, between 2005 and September 11, 2008. The accused-appellant was charged with raping his daughter, referred to as AAA, who was born on May 18, 1992. The family lived in a small hut with a makeshift curtain as a door, which did not provide adequate privacy. The first incident of sexual abuse occurred in 2005 when AAA was only 13 years old. Accused-appellant entered the hut while AAA was asleep, threatened her, and proceeded to sexually assault her. This pattern of abuse continued over the years, with AAA being raped multiple times, including specific incidents on September 11 and September 15, 2008. After the latter incident, AAA confided in her mother and aunt, leading to a report to the local authorities. The Regional Trial Court (RTC) found AAA's testimony credible and consistent with the medical findings, which indicated that she was no longer a virgin and had shallow healed lacerations. The RTC convicted Rafael Agudo y Del Valle of qualified rape on May 2, 2013, sentencing him to reclusion perpetua and ordering him to pay damages. The Court of Appeals (CA) affi...