Case Digest (G.R. No. 132783)
Facts:
The case involves the review of the decision of the Regional Trial Court of Pasig City, which found Carlos Laguerta guilty of raping eight-year-old Haidie Ecleo. Laguerta was sentenced to death. However, the prosecution failed to establish that Haidie's age was below twelve, which is an essential element of the crime of statutory rape. No birth or baptismal certificate was presented to prove Haidie's age, and there was no evidence to show that these documents were lost or destroyed. As a result, Laguerta cannot be convicted of statutory rape.
Issue:
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Ruling:
The court ruled that the prosecution failed to establish the guilt of the accused for the crime of rape. However, based on the evidence presented, the court found grounds to convict the accused of the lesser crime of acts of lasciviousness. The court explained that the acts of the accused, such as kissing the victim on the lips, sucking her nipple, holding her breast, kissing her sex organ, inserting his fing...(Unlock)
Ratio:
The court emphasized the constitutional right of the accused to be presumed innocent until proven guilty beyond a reasonable doubt. This presumption ...continue reading
Case Digest (G.R. No. 132783)
Facts:
The case of People v. Laguerta involves the accused-appellant Carlos Laguerta who was charged with rape. The Regional Trial Court (RTC) of Pasig City found him guilty beyond reasonable doubt and sentenced him to death. The court also ordered him to pay the victim, Haidie Ecleo, the amount of P300,000.00 as moral damages. The case was elevated to the Supreme Court for automatic review.
Issue:
The main issue raised by the accused-appellant is that the court erred in finding him guilty beyond reasonable doubt of the crime of statutory rape. He argues that the age of the victim was not sufficiently established. The prosecution failed to present a birth or baptismal certificate to prove the age of Haidie, and there was no showing that these documents were lost or destroyed. Therefore, the accused-appellant cannot be convicted of statutory rape.
Ruling:
The Supreme Court agrees with the accused-appellant's argument. The prosecution failed to establish the age of the victim, which is an essential element of the crime of statutory rape. Without proper documentation, the accused-appellant cannot be convicted of this crime. Furthermore, the testimony of the victim was inconsistent and lacking in detail. She repeatedly denied that the accuse...