Case Digest (G.R. No. 178323) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines vs. Armando Chingh y Parcia (G.R. No. 178323, March 16, 2011), the accused-appellant, Armando Chingh y Parcia, was charged on March 19, 2005 before the Regional Trial Court (RTC), Branch 43, Manila, with rape of a ten-year-old girl, hereinafter referred to as VVV. The Information alleged that on or about March 11, 2004, in Manila, with lewd design and by force and intimidation, Armando first inserted his fingers into VVV’s vagina and thereafter his penis, causing her serious injury and endangering her normal growth. At trial, the prosecution presented the testimony of the victim, her father, PO3 Ma. Teresa Solidarios, and Dr. Irene Baluyot, who conducted a genital examination revealing a fresh hymenal laceration with bleeding. The defense offered only Armando’s testimony denying the charges and asserting an alibi. On April 29, 2005, the RTC convicted him of statutory rape (Article 266-A(1)(d), Revised Penal Code, as amended by RA 8353) and sentenced Case Digest (G.R. No. 178323) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Charge
- Accused-appellant: Armando Chingh y Parcia.
- Victim: VVV, a ten-year-old minor.
- Information filed March 19, 2005, in Manila for rape under Art. 266-A, paragraph 1(d) (statutory rape) and paragraph 2 (rape through sexual assault).
- Transaction
- On March 11, 2004 at around 8:00 PM, VVV and playmates went to buy food. Armando approached, pulled VVV by the hand, threatened her, and led her to a vacant lot beside an unoccupied jeepney.
- There he fondled her breast, inserted his index finger into her vagina, then unzipped his pants and forcibly inserted his penis. He threatened her with death if she told anyone.
- Evidence
- Prosecution witnesses: the victim; her father; PO3 Ma. Teresa Solidarios; Dr. Irene Baluyot.
- Medical exam (March 12, 2004): fresh hymenal laceration at 6 o’clock with minimal bleeding, consistent with penetrating trauma within 24 hours; supported by photographs.
- Victim’s father observed her blood-stained underwear and odd demeanor; victim positively identified accused in a police lineup.
- Defense testimony: Armando denied commission of the acts, claimed he was en route to the market with his granddaughter, returned home due to rheumatic pain, watched TV, and was later arrested by barangay officials.
- Procedural History
- RTC Branch 43, Manila (April 29, 2005): convicted Armando of statutory rape; sentenced to reclusion perpetua; awarded P50,000 compensatory and P50,000 moral damages.
- CA (CA-G.R. CR-H.C. No. 01119, Dec. 29, 2006): affirmed RTC; additionally convicted rape through sexual assault; imposed reclusion perpetua plus indeterminate penalty; awarded P200,000 total damages.
- Supreme Court (G.R. No. 178323): parties adopted CA briefs; decision promulgated March 16, 2011.
Issues:
- Whether the evidence (victim’s testimony, medical findings, identification) is credible and sufficient to support convictions for statutory rape and rape through sexual assault.
- Whether the defenses of denial and alibi raised by accused overcome the prosecution’s evidence.
- Whether the failure to file a motion to quash the Information precludes conviction on both counts.
- What penalties properly apply, especially under R.A. No. 7610 for sexual abuse of a child under twelve.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)