Case Digest (G.R. No. 168168) Core Legal Reasoning Model
Facts:
This case involves Edgardo Dimaano (appellant), charged by his daughter Maricar Dimaano with two counts of rape and one count of attempted rape. The first charge stemmed from an incident in September 1993, where Edgardo allegedly sexually abused Maricar, then 10 years old, inside their residence in Parañaque, Metro Manila. He reportedly forced her to lie face down and inserted his penis into her anus. A few days later, appellant again raped her vaginally. These instances were kept secret by Maricar until November 1995, when she confided the abuse to her mother. On December 29, 1995, and January 1, 1996, further incidents were reported in which appellant fondled and raped her again inside their home. Maricar finally reported these abuses and filed complaints on January 26, 1996. The Medico-Legal Officer confirmed that Maricar had deep healed hymenal lacerations, indicating prior sexual abuse. Edgardo denied the allegations, asserting alibi and pointing to the presence of others
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Case Digest (G.R. No. 168168) Expanded Legal Reasoning Model
Facts:
- Parties and Charges
- Maricar Dimaano, minor daughter of Edgardo Dimaano, filed complaints against her father for two counts of rape and one count of attempted rape.
- The offenses allegedly occurred in Parañaque, Metro Manila, between 1993 and January 1, 1996.
- Criminal Case No. 96-125 charged rape in 1993; Criminal Case No. 96-150 charged rape on December 29, 1995; Criminal Case No. 96-151 charged attempted rape on January 1, 1996.
- The accused pleaded not guilty.
- Details of the Offenses
- First rape incident (1993): Appellant entered Maricar’s room, removed her clothes, and forced anal intercourse. Maricar was 10 years old.
- Subsequent rape (shortly after the first): Appellant removed clothes, positioned her on her side, and had vaginal intercourse causing great pain.
- Third rape incident (December 29, 1995): Appellant fondled and kissed Maricar’s breasts, removed her shorts and panties, fondled her vagina, and penetrated her. Maricar was 12 years old.
- Attempted rape (January 1, 1996): Appellant laid Maricar on the sofa, raised her T-shirt, kissed her breasts, attempted intercourse (while both still wearing shorts), but stopped when the mother arrived.
- Reporting and Investigation
- Maricar initially kept the incidents secret due to fear of her father.
- In November 1995, she told her mother.
- On January 3, 1996, they filed a complaint at Camp Crame on advice of a relative.
- Medical examination confirmed deep healed hymenal lacerations; Maricar was non-virgin.
- Defense of the Accused
- Denied the charges; claimed he worked mostly abroad with limited presence in the Philippines.
- Asserted alibis and presence of other people at home during alleged incidents.
- Argued that Maricar could have engaged in sexual intercourse with another man, hence he should not be automatically presumed responsible.
- Relied on a Compromise Agreement and an Affidavit of Desistance executed by Maricar, allegedly influenced by her mother.
- Trial Court Findings
- Credited the testimony of complainant for spontaneity, detail, and consistency.
- Found delay in reporting reasonable due to fear and moral ascendancy of appellant over child.
- Disregarded Compromise Agreement and desistance affidavit for lack of legal assistance and repudiation by Maricar.
- Convicted appellant of two counts of rape and one count of attempted rape; imposed penalty of reclusion perpetua, death, and prision correccional, respectively; ordered payment of damages.
- Court of Appeals
- Affirmed conviction with modifications in damages, specifically separate awards of civil indemnity, moral damages, and exemplary damages for each count.
- Certified appeal on death penalty charge to Supreme Court.
Issues:
- Whether the prosecution evidence overcame the presumption of innocence of the accused.
- Whether the voluntary and due execution of the affidavit of desistance by the complainant should have been considered to cast doubt on the prosecution’s charges and warrant dismissal or acquittal.
- Whether the complaint for attempted rape was sufficient in form and substance to support conviction.
- Proper penalties and awards of damages for the crimes charged.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)