Title
People vs. Agustin
Case
G.R. No. 175325
Decision Date
Feb 27, 2008
Conchito Agustin is convicted for two counts of rape on a minor, with the Supreme Court upholding the conviction based on the credible testimony of the victim and discrediting the appellant's alibi, resulting in a modification of the conviction from qualified rape to simple rape.
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Case Digest (G.R. No. 175325)

Facts:

  • Conchito Agustin faced two counts of qualified rape against AAA, a minor.
  • The first incident occurred on July 7, 2001, when AAA was nearly 12 years old; Agustin raped her after forcibly removing her clothing.
  • The second incident took place on July 19, 2001, where Agustin threatened AAA to keep silent about the assault.
  • AAA disclosed the incidents to her mother and family, leading to a medico-legal examination that confirmed sexual assault.
  • The Regional Trial Court found Agustin guilty and initially imposed the death penalty due to AAA's age and Agustin's relationship as her uncle.
  • Agustin denied the allegations, claiming an alibi for both incidents.
  • The trial court found AAA's testimony credible, leading to conviction.
  • The Court of Appeals upheld the trial court's decision, prompting Agustin to appeal to the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court affirmed Agustin's conviction for two counts of simple rape but modified the charges from qualified rape to simple rape.
  • The Court determined that while rape was established, the relationship necessary for qualified rape was not proven beyond a reasonable doubt.
  • Agustin was sentenc...(Unlock)

Ratio:

  • The Supreme Court emphasized that credible victim testimony is often sufficient for a rape conviction.
  • AAA's testimony was consistent and credible, with no apparent motive for her to fabricate the allegations.
  • Agustin's alibi was deemed weak due to the short distance between his farm and home.
  • The prosecution failed to prove the relationship between Agustin and AAA beyon...continue reading

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