Case Digest (G.R. No. 205200)
Facts:
People of the Philippines v. Leonardo Cruz y Roco, G.R. No. 205200, September 21, 2016, Supreme Court Third Division, Perez, J., writing for the Court.On January 11, 2006 a criminal information for rape under Article 266-A(1)(a) of the Revised Penal Code was filed against appellant Leonardo Cruz y Roco before the Regional Trial Court (RTC) of Pasig City (Criminal Case No. 132364-H, Branch 159). The complaint alleged that on January 2, 2006 the appellant raped his thirteen-year-old goddaughter and piano tutee, AAA, by force, threat and intimidation. The appellant pleaded not guilty and trial ensued.
The prosecution presented AAA’s testimony recounting that the appellant fetched her from school, took her to a motel in Pasig (Queen’s Court), removed both their clothes, lay on top of her with his "organ" directly in front of hers, and that she felt something penetrate her "organ"; the incident allegedly lasted 15–20 minutes and the appellant threatened to kill her if she screamed. AAA reported the incident to her parents two days later. The prosecution also offered medico-legal reports and testimony by Dr. Joseph C. Palmero, who found healed lacerations on AAA’s hymen and no spermatozoa in vaginal smears.
The defense presented the appellant’s denial and an alternative narrative: that he was in a consensual relationship with AAA since December 2005, that he visited an apartment with AAA on January 2 and left the same day, and that photographs and corroborating testimony (from his wife Lea and friend Tristan) showed intimacy rather than force. The defense also called Preciosa Gillado Landrito (school principal) and Edwin Cenita (OIC of the motel) to dispute parts of AAA’s account: Preciosa testified the school had no sanctioned activities on January 2, 2006; Edwin said he knew of no motel incidents from 2003–2008. The RTC, on March 30, 2010, convicted appellant of rape and sentenced him to reclusion perpetua and ordered damages (P50,000 civil, P50,000 moral, P25,000 exemplary). The Court of Appeals affirmed in a decision promulgated January 24, 2012. The appellant filed an ordinary appeal to the Supreme Court pursuant...(Subscriber-Only)
Issues:
- Was the testimony of the victim, AAA, sufficient to prove rape under Article 266‑A(1)(a) of the Revised Penal Code?
- Should AAA’s testimony be disbelieved because it was contradicted by the testimonies of defense witnesses and the medico‑legal findings?
- Should the damages awarded by the RTC and affirmed by the Court of Appeals be modified?
- Should the appellant’s motion t...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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