Case Digest (G.R. No. 248049) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines vs. Efren Agao y Anonuevo (G.R. No. 248049, October 4, 2022), appellant Efren Agao was charged by two Informations dated October 27, 2014 in Valenzuela City with statutory rape under Articles 266-A(1) and 266-B of the Revised Penal Code, as amended by R.A. 8353, in conjunction with R.A. 7610. In Criminal Case No. 1453-V-14, it was alleged that sometime in July 2010, Agao—then step-father of the minor victim “AAA,” born December 6, 1999—willfully and by force and intimidation had sexual intercourse with the 10-year-old AAA. In Criminal Case No. 1454-V-14, it was charged that in January 2012, appellant likewise had sexual intercourse with AAA, who was then 13 years old. During trial, AAA testified that her mother BBB and father CCC were separated, that BBB lived with appellant, and that physical and sexual abuse commenced in 2009 when appellant first touched her genitals during bathing. On a July 2010 morning, AAA woke to appellant’s hand on her breast... Case Digest (G.R. No. 248049) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Procedural History
- On October 27, 2014, two Informations were filed in RTC Branch 172, Valenzuela City, charging Efren Agao y Anonuevo (appellant) with statutory rape under Art. 266-A, par. 1 and Art. 266-B, RPC as amended by R.A. 8353 in conjunction with R.A. 7610:
- Crim. Case No. 1453-V-14: victim AAA, then 10 years old (b. Dec. 6, 1999), allegedly raped in July 2010.
- Crim. Case No. 1454-V-14: same victim, then 13 years old, allegedly raped in January 2012.
- Appellant, AAA’s stepfather, pleaded not guilty at arraignment.
- Trial Evidence
- AAA’s background: born Dec. 6, 1999; parents separated; lived with her mother’s partner, appellant.
- Onset of abuse: in 2009 (age 10), appellant began touching AAA’s genitals while bathing her.
- July 2010 incident (age 10): AAA awoke to appellant fondling her breasts and vagina; he attempted to insert his erect penis, touching her labia majora but could not fully penetrate due to her resistance.
- January 2012 incident (age 13): similar assault while AAA slept; repeated attempts, erect penis touched labia majora, no full penetration.
- Delay in reporting: AAA did not disclose the assaults to anyone, including her mother, for fear of disbelief and harm, until June 2014.
- Medical examination by PCI Cruz: no fresh genital injuries; expert testified that hymenal lacerations may heal, and an erect penis touching labia often causes no laceration.
- Defense testimony: appellant denied offenses; alleged AAA was coached by her father; noted AAA’s visits during his detention.
- Lower Court Rulings
- RTC (March 15, 2017): found appellant guilty beyond reasonable doubt of two counts of statutory rape; imposed reclusion perpetua per count; awarded moral, civil, and exemplary damages.
- CA (Jan. 15, 2019): affirmed conviction; increased damages; agreed that slight penetration (erect penis touching labia) consummates rape; declined to apply stepfather–stepdaughter qualifying circumstance for lack of proof of legal marriage.
Issues:
- Core Issue
- Whether the CA correctly affirmed appellant’s conviction for two counts of rape through sexual intercourse under Art. 266-A, par. 1 and Art. 266-B, RPC as amended by R.A. 8353, in conjunction with R.A. 7610.
- Appellant’s Contentions
- No consummated rape—insufficient proof of penetration.
- Victim’s testimony was inconsistent and lacked credibility.
- Unreasonable delay in reporting renders the allegations doubtful.
- People’s Position
- RTC and CA properly credited AAA’s positive, consistent testimony.
- Proof of slightest penetration (erect penis touching labia) sufficient for consummated rape.
- Delay was reasonably explained by fear and coercion; damages awards appropriate.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)