Case Digest (G.R. No. 210619)
Facts:
People of the Philippines v. Charles Reyes y Marasigan, G.R. No. 210619, August 20, 2014, Supreme Court First Division, Reyes, J., writing for the Court.The prosecution charged Charles Reyes y Marasigan (accused-appellant), the common-law husband of BBB, with two counts of rape by information before the Regional Trial Court (RTC) of Calapan City (Criminal Case Nos. C-02-6987 and C-02-6988). The complaints alleged two separate incidents against AAA, the 11-year-old daughter of BBB, occurring sometime in May 2002 and on August 5, 2002, both at their residence in Barangay Calero, Calapan City. The accused pleaded not guilty.
At the joint trial the prosecution offered AAA’s birth certificate, a medical certificate dated August 7, 2002 prepared by Dr. Ma. Teresita Nieva-Bolor, and affidavits of AAA and BBB; the defense offered only AAA’s birth certificate. Witnesses for the prosecution were AAA, BBB, and Dr. Nieva-Bolor. The accused and his 13-year-old niece, Princess Ann Sicat, testified for the defense. AAA testified in detail about both incidents, describing undressing, the accused mounting her and making pumping motions that caused pain; she stated that in the May incident the accused tried to insert his penis and that she felt pain.
Dr. Nieva-Bolor’s examination reported vulvar erythema and hymenal lacerations—an incomplete laceration at 3:00 o’clock and healed lacerations at 5, 6, 8 and 9 o’clock positions—findings the prosecution contended corroborated sexual abuse. The accused denied the charges, claiming fabrication motivated by domestic conflict and presented testimony (Sicat) that contradicted AAA’s account of the August incident.
On November 25, 2009, the RTC convicted the accused of two counts of rape under paragraph 1(a) of Article 266-A of the Revised Penal Code (RPC) and sentenced him to two terms of reclusion perpetua, ordering indemnities and damages (civil indemnity P100,000; moral damages P75,000; exemplary damages P50,000). The Court of Appeals (CA) in CA-G.R. CR-H.C. No. 04374 affirmed the RTC’s decision in toto on July 10, 2013, finding AAA’s testimony credible and ...(Subscriber-Only)
Issues:
- Should the Supreme Court disturb the RTC’s and CA’s factual findings and credibility determinations?
- Whether the elements of statutory rape under Article 266-A(1)(d) RPC were proven beyond reasonable doubt for the two alleged incidents.
- Whether the rape convictions are qualified by the accused’s relationship to the victim (common-law husband of the victim’s mother) and what penalty applies.
- Whether the damages awarded by the courts a quo should be modif...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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