Title
People vs. Ferdez
Case
G.R. No. 140203
Decision Date
Jan 31, 2002
A 9-year-old girl was raped by her uncle, Eddie Fernandez. Medical evidence and her credible testimony led to his conviction, upheld by the Supreme Court, with reclusion perpetua and damages awarded.

Case Digest (G.R. No. 247819)
Expanded Legal Reasoning Model

Facts:

  • Background of the Case
    • The case involves Eddie S. Fernandez, the accused, and AAA, a nine-year-old girl, who is the victim of rape.
    • Eddie Fernandez is related to the victim as her uncle (being the cousin of her father).
    • Despite owning a house, Eddie Fernandez frequently visited the residence of BBB, the victim’s aunt, where AAA was staying.
  • Commission of the Crime
    • The incident occurred sometime in November 1997 when AAA was at BBB’s house.
    • While BBB was occupied with household chores near a brook, Eddie Fernandez sent AAA together with other children (referred to as her brothers and sisters) to their aunt CCC’s house, located about seventy-five meters away.
    • Once AAA was left alone, Eddie Fernandez raped her.
    • Later, while BBB was boiling water, she observed AAA and her sister playing with Eddie Fernandez’s private parts.
    • Upon inquiry, AAA disclosed that Eddie Fernandez raped her on several occasions.
  • Aftermath and Investigation
    • AAA’s account was communicated by Marilyn and Fely to her father, prompting the filing of a police complaint against Eddie Fernandez.
    • On December 16, 1997, a doctor conducted a medical examination on AAA, which revealed that:
      • AAA was no longer a virgin, showing an elastic, fleshy hymen with deep healed laceration at the 5 o’clock position.
      • There were no external signs indicating the application of force or physical violence.
    • On the same day as the medical examination, AAA lodged a formal complaint for rape at the Municipal Trial Court.
    • A preliminary investigation was subsequently conducted by a municipal judge.
  • Prosecution and Trial Proceedings
    • On March 2, 1998, the Provincial Prosecutor filed an information for rape with the Regional Trial Court based on AAA’s testimony and the corroborative medico-legal report.
    • The charge was framed under the provisions of the Revised Penal Code (Article 266-A with its amendment by R.A. 8353) in conjunction with Section 5(b) of R.A. 7610.
    • Eddie Fernandez was arraigned on June 2, 1998, and entered a plea of not guilty.
    • After a trial that involved the direct testimony of AAA and other supporting evidence, on August 9, 1999, the trial court rendered its decision:
      • Convicting Eddie Fernandez of rape.
      • Imposing reclusion perpetua as his sentence.
      • Ordering the payment of civil indemnity of P50,000.00 to the victim.
  • Evidentiary Basis and Supporting Testimonies
    • AAA’s testimony was presented in detail before the court, recounting the events leading to and during the rape.
    • The examination of the victim’s private parts and the physical evidence found there corroborated her narrative.
    • The consistency and directness of AAA’s statements reinforced the prosecution’s case against the accused.
    • The defense’s reliance on alibi and denial was not substantiated by any evidence that could weaken the victim’s clear and unequivocal testimonial account.

Issues:

  • Evidentiary Sufficiency and Credibility
    • Whether the prosecution succeeded in proving the guilt of Eddie Fernandez beyond reasonable doubt.
    • Whether the credibility of the victim’s testimony, despite her young age, was sufficient to establish the occurrence of rape.
  • Assessment of Defense Arguments
    • The effectiveness and viability of the accused’s defense of alibi and denial.
    • How the court should weigh the victim’s consistent and detailed account against the defense’s attempts to introduce doubt.
  • Procedural and Evidentiary Considerations
    • The impact of the absence of the doctor’s live testimony in court despite the availability of the medico-legal report.
    • Whether the lack of presentation of certain evidentiary witnesses could affect the overall verdict.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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