Case Digest (G.R. No. 208749) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines v. Anecito Estibal y Calungsag, the Regional Trial Court (RTC) of Pasig City (stationed in Taguig City), Branch 69, convicted Anecito Estibal y Calungsag on November 24, 2011 for raping his thirteen-year-old daughter, AAA, on February 5, 2009 in Taguig City under Article 266-A(2) and Article 266-B(5)(1) of the Revised Penal Code as amended by R.A. No. 8353 and Section 5(a) of R.A. No. 8369. The Information charged him with exploiting his moral ascendancy to have unlawful sexual intercourse with AAA, a minor. He pleaded not guilty at arraignment on March 9, 2009. At pre-trial, his wife BBB, AAA’s mother, withdrew her support, stating AAA had forgiven her father, but the court denied desistance. During trial, the prosecution presented four witnesses by stipulation: Dr. Jesille Baluyot, who conducted the medico-legal examination diagnosing previous blunt force trauma to the hymen; Barangay Security Force members Michael Estudillo and Ronillo Perlas, who Case Digest (G.R. No. 208749) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Procedural History
- The People of the Philippines charged Anecito Estibal y Calungsag with rape under Article 266-A(2), in relation to Article 266-B(5)(1) of the Revised Penal Code, as amended by R.A. No. 8353 and R.A. No. 8369.
- The Regional Trial Court (RTC), Branch 69, Pasig City (stationed in Taguig City), convicted him by decision dated November 24, 2011. The Court of Appeals (CA) affirmed on March 25, 2013. The case is before the Supreme Court on automatic review.
- Evidence at Trial
- Information alleged that on February 5, 2009, accused used force, violence, intimidation and moral ascendancy to have sexual intercourse with his 13-year-old daughter (AAA) against her will, qualifying the crime by relationship, minority, abuse of dwelling and superior strength.
- Prosecution witnesses (testimonies stipulated):
- Dr. Jesille Baluyot (medico-legal examiner) – initial report showed healed anogenital lacerations diagnostic of blunt force or penetrating trauma to the hymen.
- BSF Michael Estudillo & BSF Ronillo Perlas (Barangay Security Force) – arrested the accused without warrant after AAA and her mother (BBB) reported the abuse.
- PO3 Fretzie S. Cobardo (PNP Women and Children Protection Center) – took AAA’s sworn statement late evening of February 5, 2009; testified AAA was crying, uncoached, and spontaneously narrated repeated abuse since Grade III.
- Accused’s defense was general denial and alibi: he claimed he was asleep with his children between 1 a.m. and 2 a.m., and that others influenced AAA to file the complaint.
- AAA and BBB failed to appear at trial despite subpoenas; AAA had moved to an unknown address.
Issues:
- Whether AAA’s out-of-court statements to barangay tanods and to PO3 Cobardo are admissible under the res gestae exception to the hearsay rule.
- Whether, in the absence of the complainant’s in-court testimony and relying on hearsay and circumstantial evidence, the prosecution proved the accused’s guilt beyond reasonable doubt.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)