Case Digest (G.R. No. 192820)
Facts:
People of the Philippines v. Renato Dela Cruz, G.R. No. 192820, June 04, 2014, First Division, Leonardo‑De Castro, J., writing for the Court. The plaintiff-appellee is the People of the Philippines; the accused-appellant is Renato dela Cruz.In two separate Informations filed before the Regional Trial Court (RTC) of Malolos, Bulacan (Criminal Case Nos. 3253‑M‑2004 and 3254‑M‑2004), the accused was charged with rape for an incident alleged to have occurred on September 9, 2003, and with rape for an incident alleged to have occurred in October 1999; both offenses were said to have been committed against his daughter, identified in the record as AAA. The accused pleaded not guilty.
At trial the prosecution presented the testimony of AAA (the victim) and BBB (her elder sister), and introduced a medico‑legal report concluding that AAA was in a non‑virgin state physically. The accused testified in his own defense and denied the allegations, asserting family animosity and prior quarrels as motive for fabrication. The RTC, in its Decision dated September 24, 2007, found the accused guilty of qualified rape for the September 9, 2003 incident and guilty of the lesser offense of acts of lasciviousness for the October 1999 episode; it imposed reclusion perpetua for the rape count and an indeterminate term for acts of lasciviousness, and ordered indemnities of P100,000 and P50,000 respectively.
The accused appealed to the Court of Appeals, which in a Decision dated November 20, 2009 affirmed the RTC with modifications: in Criminal Case No. 3253‑M‑04 it affirmed conviction for rape and sentenced the accused to reclusion perpetua with no possibility of parole and awarded P75,000 civil indemnity, P75,000 moral damages and P30,000 exemplary damages; in Criminal Case No. 325...(Subscriber-Only)
Issues:
- Did the alleged ill motive of AAA and BBB and the inconsistencies in AAA’s testimony destroy their credibility so as to overturn the convictions?
- Were the elements of (a) qualified rape (September 9, 2003) and (b) acts of lasciviousness (October 1999) proven beyond reasonable doubt?
- What penalties and damages should be imposed, considering applicab...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)