Facts:

• On December 19, 2000, the Regional Trial Court of Urdaneta City, Branch 46, convicted Freddie Fontanilla of rape in Criminal Case Nos. U-10628 and U-10629, imposing the death penalty.
• The charges arose from incidents in November 1999 and January 2000, where Fontanilla, the stepfather of 14-year-old complainant AAA, allegedly raped her using force, threats, and intimidation.
• The first incident occurred when Fontanilla entered AAA's room at night, removed her clothing, and assaulted her.
• The second incident followed a similar pattern, occurring in the presence of AAA's half-siblings.
• AAA did not report the assaults immediately due to threats made by Fontanilla against her mother.
• On April 14, 2000, AAA, with her mother, reported the incidents to the police and filed formal complaints.
• The trial court found AAA's testimony credible despite defense claims of fabrication and the testimony of her mother, Esmeralda, who supported Fontanilla.
• Fontanilla was sentenced to death and ordered to pay damages to AAA.
• He later filed a motion for a new trial based on an affidavit of recantation from AAA, which the trial court denied.
• The case was automatically reviewed by the Supreme Court.

Issue:

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Ruling:

• The Supreme Court affirmed Freddie Fontanilla's conviction for rape in both cases but modified the penalty from death to reclusion perpetua.
• The Court ord...(Unlock)

Ratio:

• The Supreme Court upheld the trial court's findings, emphasizing the credibility of AAA's detailed and consistent testimony.
• The presence of AAA's half-siblings did not negate the possibility of rape, as such crimes can occur despite the risk of being discovered.
• The Court found the motive attributed to AAA for fabricating charges implausible, considering her age and innocence.
• The affidavit of recantation did not qualify as newly discovered evidence, failing to meet the criteria for a new trial....continue reading