Facts:

The case at hand involves the defendant-appellant Anecito Estebal and the plaintiff-appellee, the People of the Philippines. The incident reportedly occurred in January 1986 in Barangay Dalangin, Titay, Zamboanga del Sur. At the center of the case is a tragic complaint of rape concerning a thirteen-year-old girl, Wilma Legaspi, who was the daughter of Thelma Legaspi. Wilma's mother, Thelma, uncovered her daughter's enlarging abdomen, which led to the revelation that Wilma had been sexually abused by her uncle, the accused, Anecito Estebal. Upon examination by a physician, it was revealed that Wilma was six months pregnant as a result of the assaults she had endured.

A complaint for rape was duly filed with the Municipal Trial Court, wherein a warrant for Estebal’s arrest was subsequently issued. Following preliminary investigations, the case was escalated to the Regional Trial Court with an information charging Estebal with rape. Specifically, it was alleged that on nume

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Facts:

Incident Discovery and Background

• The case involves a young girl, Wilma Legaspi, aged thirteen, who was allegedly raped and repeatedly abused by her uncle and neighbor, Anecito Estebal y Lapidante.
• Wilma Legaspi is the daughter of Thelma Legaspi, who later discovered her daughter’s suspiciously enlarging abdomen.
• A medical examination confirmed that Wilma was six months pregnant, substantiating the suspicions of abuse.

Initiation of Proceedings

• Upon suspicion and confirmation of pregnancy, a complaint for rape was filed before the Municipal Trial Court.
• A warrant of arrest was issued by the municipal judge, and the preliminary investigation led to the case being forwarded to the Provincial Fiscal.
• The accused was charged in the Regional Trial Court with rape, detailed in the information as committed with use of force and intimidation, notably wielding a sharp bolo.

Testimonies and Accounts

• Complainant Wilma Legaspi testified that in January 1986, while on her way back to school, she was accosted by Anecito Estebal who, with a bolo in hand, dragged her into the hagonoy bushes and threatened to kill her if she resisted.
• She recounted that the accused removed both her panty and his pants, forced her to lie down, and performed sexual intercourse against her will.
• Wilma further testified that she was raped a total of five times over the months of January, February, and March 1986.
• Thelma Legaspi, her mother, corroborated the testimony by describing how she discovered the pregnancy and how she and her husband sought help from their barangay captain, leading to the investigation and arrest of the accused.
• The accused, Anecito Estebal, testified that he had known the complainant from a long period as neighbors and distant relatives. He admitted to having sexual intercourse with her—albeit asserting that it was consensual and that she seduced him—claiming that such encounters occurred up to 150 times over a few months, usually in the hagonoy bushes during their lunch break.

Evidence Presented

• Documentary evidence was introduced, including the medical findings confirming the victim’s pregnancy and other exhibits relating to the investigation.
• The consistency between the testimonies of Wilma Legaspi and her mother, as well as the physical evidence, were key to the consolidation of the prosecution’s case.

Trial Court Decision

• Based on the testimonies and documentary evidence, the trial court found Anecito Estebal guilty of rape beyond reasonable doubt.
• The court sentenced him to reclusion perpetua and ordered him to pay damages to the victim—initially set at P20,000.00—together with the costs of the proceedings.

Issue:

Credibility of the Victim’s Testimony

• Whether the trial court erred in giving credence to Wilma Legaspi’s testimony in light of her young age and alleged inexperience.
• The reliability of a testimony that recounts traumatic events involving a minor in the context of an inherently sensitive and complex rape case.

Establishment of Force and Intimidation

• Whether the elements of force and intimidation, as required under Article 335 of the Revised Penal Code, were sufficiently proven beyond reasonable doubt.
• The significance and impact of the complainant’s account of threatened violence (e.g., the use of the bolo and threats to kill) against the accused’s version of a consensual encounter.

Sufficiency of the Prosecution’s Evidence

• Whether the prosecution succeeded in proving the accused’s guilt beyond reasonable doubt, especially given the accused-appellant's counter-testimony and admission of sexual relations.
• The role of the accused’s version—claiming seduction and consensual intercourse—in casting doubt on the application of force and intimidation.

Appropriate Quantum of Damages

• Whether the initial award of damages (P20,000.00) should be re-evaluated and increased in light of recent similar cases and evolving jurisprudence.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)