Title
Supreme Court
People vs. Llanita y Opiana
Case
G.R. No. 134101
Decision Date
Sep 5, 2001
Accused convicted of qualified rape of a 5-year-old; death penalty upheld based on credible child testimony, despite lack of fresh injuries or birth certificate.

Case Digest (G.R. No. 134101)
Expanded Legal Reasoning Model

Facts:

  • Circumstances of the Case
    • The accused, Felino Llanita y Opiana, was charged with the rape of a five-year-old girl named Catherine Acol.
    • The alleged rape occurred on March 25, 1996.
    • Catherine testified that she was raped on three occasions by the accused; the charge was for the third alleged rape.
  • Defense and Trial
    • The accused denied the rape and presented an alibi, asserting he was working at a repair shop from 7:00 a.m. to 5:00 p.m. on the date in question.
    • The trial court found the accused guilty beyond reasonable doubt and sentenced him to death.
    • The accused appealed, claiming that the prosecution failed to prove his guilt beyond reasonable doubt.
  • Medical Examination
    • Catherine was examined by Dr. Armie Loreta the day after the alleged rape; no fresh lacerations were found, but "old healed complete hymenal lacerations" were present, indicating previous sexual abuse.
    • The medical report did not show physical injuries corroborating the alleged incident, but confirmed the possibility of penetration of the male organ despite Catherine’s tender age.
  • Age of the Victim
    • The prosecution's evidence on Catherine’s age consisted primarily of her own testimony that she was five years old.
    • The accused admitted that Catherine was five years old in 1996, claiming she was his niece.
    • Official birth certificate was submitted to this Court only after initial proceedings, confirming Catherine’s birth on June 19, 1990.

Issues:

  • Whether the trial court erred in convicting the accused despite the alleged failure of the prosecution to prove guilt beyond reasonable doubt.
  • Whether the testimony of the child-victim, including her identification of the accused as the rapist, is credible and sufficient as sole evidence.
  • Whether the medical findings contradict the victim’s testimony on the commission of rape.
  • Whether the prosecution sufficiently established the victim’s age to qualify the crime for the death penalty, given the absence of initial documentary evidence proving age.
  • Whether the imposition of the death penalty under R.A. 7659 is justified in this case.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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