Title
People vs. Orande y Chavez
Case
G.R. No. 141724-27
Decision Date
Nov 12, 2003
Arnulfo Orande was convicted of two counts of statutory rape and two counts of simple rape, with the Supreme Court affirming the absence of a crime defined as frustrated rape and confirming that any penetration suffices for conviction.
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Case Digest (G.R. No. 141724-27)

Facts:

  • The case involves the People of the Philippines (appellee) and Arnulfo Orande y Chavez (appellant).
  • The appeal is from the Regional Trial Court of Manila, Branch 18, dated November 12, 2003.
  • The appellant was convicted of two counts of simple rape, one count of statutory rape, and one count of frustrated rape.
  • Sentences included reclusion perpetua for simple and statutory rapes, and an indeterminate penalty of 8 years to 14 years and 8 months for frustrated rape.
  • The complainant, referred to as AAA, accused the appellant of raping her four times between January 1994 and November 1996.
  • The first incident occurred on April 15, 1994, when AAA was nine years old, involving threats with a knife and partial penetration.
  • The second incident was on March 12, 1995, when AAA was 11 years old, with similar threats and actions.
  • The third incident took place on January 14, 1996, when AAA was 12 years old, again involving threats and forced sexual acts.
  • The final incident occurred in November 1996, where the appellant attempted to rape AAA but was interrupted.
  • AAA's testimony was supported by medical evidence indicating signs of trauma consistent with sexual abuse.
  • The trial was delayed for eight months to allow AAA to undergo psychological therapy due to trauma.
  • The appellant denied the allegations, claiming an alibi and suggesting AAA had motives to fabricate charges.

Issue:

  • (Unlock)

Ruling:

  • The court affirmed the trial court's conviction of the appellant for two counts of statutory rape and two counts of simple rape.
  • The court agreed with the appellant's contention that t...(Unlock)

Ratio:

  • The Supreme Court upheld the trial court's findings, emphasizing the credibility of AAA's testimony, which was convincing and consistent despite her trauma.
  • The court noted the trial court's unique opportunity to observe AAA's demeanor during her testimony, reflecting her emotional distress and desire for justice.
  • The court rejected the appellant's defense of denial and alibi, stating such defenses are weak against the positive identification and testimony of a rape victim.
  • Regarding frustrated rape, the co...continue reading

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