Case Digest (G.R. No. 219111)
Facts:
In the case of People of the Philippines v. Nelson Nuyte y Asma (G.R. No. 219111, March 12, 2018), the accused, Nelson Nuyte y Asma, was charged with one count of rape and five counts of violation of Section 5(b) of Republic Act No. 7610. The accusations stemmed from incidents occurring in April and May 2004 in the Province of Albay, Philippines. The victim, referred to as “AAA,” was 14 years old at the time of the first incident, which allegedly occurred on April 10, 2004. The rape was reportedly committed under threats, with the accused brandishing a knife to intimidate the victim.The prosecution's version of events detailed a pattern of coercive sexual acts by Nuyte against the victim. Following threats that he would harm both AAA and her mother if she sought help, the accused was said to have lured her into secluded areas, resulting in multiple instances of sexual assault identified by specific dates: April 10, April 12, April 14, April 19, May 3, and May 6 of 2004. Af
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Case Digest (G.R. No. 219111)
Facts:
- Charges and Informations
- Appellant Nelson Nuyte y Asma was charged in six separate Informations:
- One count of rape under Article 266-A of the Revised Penal Code (Criminal Case No. FC-00-780).
- Five counts of violation of Section 5(b) of Republic Act No. 7610 (Criminal Cases Nos. FC-00-781 to FC-00-785).
- The Informations detailed that on various dates in 2004—April 10, April 12, April 14, April 19, May 3, and May 6—the accused allegedly committed acts involving sexual intercourse with a 14-year-old victim known as “AAA” at knifepoint, using force, intimidation, and coercion.
- Alleged Incidents and Chronology of Events
- April 10, 2004 (Criminal Case No. FC-00-780)
- “AAA” was tending to household chores (e.g., tethering cows).
- The accused suddenly appeared, grabbed her by the hair, and, armed with a knife, forced her to lie down.
- He removed her undergarment and, through force, inserted his penis into her vagina.
- April 12, 2004; April 14, 2004; and April 19, 2004 (Criminal Cases Nos. FC-00-781, FC-00-784, respectively)
- Similar incidents were alleged wherein the accused employed intimidation and coercion.
- “AAA” stated these incidents occurred under circumstances resembling the April 10 event, although some testimonies were summarized with less detail.
- May 3, 2004 and May 6, 2004 (Criminal Cases Nos. FC-00-783 and FC-00-782)
- The accused allegedly moved “AAA” to a different site farther from his residence, where he again employed a knife as an instrument of threat.
- Detailed questioning by the prosecution recounted the sequence of events including removal of garments and forcible sexual acts.
- Testimonies and Presentation of Evidence
- Prosecution’s Evidence
- “AAA’s” testimony was central, describing in detail the moments of coercion—appearance, physical restraint, showing a knife, and execution of the sexual act.
- Physical findings (multiple healed and recent hymenal lacerations) corroborated the testimony.
- Defense’s Evidence and Assertions
- The accused claimed a consensual relationship that began around December 2003, based on alleged exchanges (including a love letter) between him and “AAA.”
- The defense asserted that the incidents were marital or lovemaking affairs and argued that delays in reporting or absence of overt physical injuries were not indicative of rape.
- The defense relied heavily on the narrative that “AAA,” having developed a relationship with him, was willing and that the domestic disputes were triggered by the victim’s family’s disapproval.
- Trial Court and Appellate Proceedings
- Regional Trial Court Decision (December 9, 2011)
- Found the appellant guilty beyond reasonable doubt of rape in Criminal Case No. FC-00-780.
- Also convicted him for five counts of violation of Section 5(b) of RA 7610 based on the repeated sexual abuse of a minor.
- Imposed penalties of reclusion perpetua for rape and imprisonment ranging from 8 years and 1 day to 17 years, 4 months and 1 day for the child abuse counts.
- Ordered payment of civil indemnity, moral damages, and exemplary damages against “AAA.”
- Court of Appeals Decision (September 25, 2014)
- Affirmed the conviction in six cases.
- Rejected the appellant’s contentions regarding the credibility of “AAA,” the nature of the alleged consensual relationship, and issues of delayed disclosure.
- Upheld both the conviction and the penalty impositions despite arguments about lack of resistance, timing of classes, and severity of physical injury.
- Supreme Court Ruling (March 12, 2018)
- Partly granted the appeal.
- Modified the decision by:
- Upholding the conviction of rape in Criminal Case No. FC-00-780 as the evidence clearly established force and intimidation.
- Acquitting the appellant in Criminal Case Nos. FC-00-781, FC-00-784, and FC-00-785 due to insufficiency of detailed evidence regarding the commission of those specific acts.
- Reclassifying the charges in Criminal Cases FC-00-782 and FC-00-783 as rape, with penalties accordingly imposed.
- Upheld the pecuniary liabilities (civil indemnity, moral damages, and exemplary damages with interest) with modifications based on prevailing jurisprudence.
Issues:
- Credibility of the Victim’s Testimony
- Whether the delay in reporting the incidents negatively impacted the credibility or reliability of “AAA’s” testimony.
- Whether the absence of extensive physical injuries undermines the factual basis of the alleged rape.
- Nature of the Relationship and Consent
- Whether the purported “sweetheart” relationship between the accused and “AAA” is sufficient to imply consent.
- Whether the evidence supports the defense’s claim that the sexual encounter was consensual.
- Double Jeopardy and Charging of Offenses
- Whether the appellant can be charged concurrently with both rape (under Article 266-A, RPC) and child abuse (under Section 5(b) of RA 7610) for the same act.
- The appropriate charge when the victim is 14 years old, based on established jurisprudence.
- Evidence and Proof of Each Incident
- Whether the evidence presented by the prosecution satisfactorily establishes the details of each separate act.
- Whether the lack of detailed testimony in certain incidents justifies an acquittal on those counts.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)