Title
People vs. Maglente y Cervantes
Case
G.R. No. 179712
Decision Date
Jun 27, 2008
In summary, the Supreme Court affirmed the conviction of Efren Maglente for the rape of his fourteen-year-old daughter. The Court found the victim's testimony to be credible and emphasized the importance of considering the young age and immaturity of the victim in assessing her testimony. The Court rejected the appellant's argument that the victim's narration lacked details, explaining that the testimony of a minor should be viewed in light of their limited understanding of sex and sexuality. The Court also held that the absence of violence or resistance from the victim does not affect the outcome of the case when a father commits rape against his own daughter.
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Case Digest (G.R. No. 179712)

Facts:

  • The appellant, Efren Maglente y Cervantes, was convicted of raping his fourteen-year-old daughter, AAA.
  • The incident occurred on July 13, 2002, in Rodriguez, Rizal.
  • Maglente was charged with Rape under paragraph 1 of Article 266-A, in relation to number 1 of paragraph 6 of Article 266-B of the Revised Penal Code, as amended by Republic Act No. 8369.
  • The victim testified that her father had been sexually abusing her since she was nine years old, with the last incident on July 13, 2002.
  • The prosecution presented testimonies from the victim, her aunt CCC, and a medico-legal officer, Police Senior Inspector Ruby Grace Sabino.
  • The medico-legal officer confirmed the victim's pregnancy and physical injuries consistent with sexual abuse.
  • The RTC found Maglente guilty beyond reasonable doubt, sentencing him to death and ordering him to pay damages.
  • The Court of Appeals affirmed the RTC's decision but modified the penalty to reclusion perpetua due to Republic Act No. 9346, which prohibits the death penalty.
  • The appellant filed an appeal before the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court denied the appeal and affirmed the decision of the Court of Appeals.
  • The appellant was found guilty beyond reasonable doubt of qualified rape.
  • The appellant was sentenced to reclusion perpetua.
  • The appellant was ordered to pa...(Unlock)

Ratio:

  • The Supreme Court upheld the conviction based on the credibility of the victim's testimony, which was categorical, straightforward, and consistent.
  • The testimony of a young and immature girl against her parent is given full weight and credit, especially in cases of incestuous rape.
  • The Court rejected the appellant's argument that the victim's narration lacked details, explaining that the testimony of a minor should be viewed in light of their limited understanding of sex and sexuality.
  • The absence of violence or resistance from the victim does not affect the outcome of the case when a father commits rape against his own daughter, as the father's moral ...continue reading

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