Case Digest (G.R. No. 137037-38)
Facts:
- Virgilio Romero was convicted of two counts of rape against his step-granddaughter, Marilou Romero.
- The incidents occurred in April 1996 in Barangay Apad, Polangui, Albay, Philippines.
- The Regional Trial Court of Ligao, Albay, sentenced Romero to death on December 17, 1998, under Article 335 of the Revised Penal Code, as amended by Republic Act No. 7659.
- The prosecution filed two separate informations on September 12, 1997, alleging that Romero had carnal knowledge of Marilou against her will.
- Marilou, who was 15 years old at the time of the trial, testified that she had lived with Romero and his common-law wife, Flora, since she was one year old.
- She reported that the first rape occurred when she was ten years old in Batangas, with subsequent incidents happening in Polangui when she was thirteen.
- The prosecution presented witnesses, including Rodolfo Sameniano (barangay chairman) and Dr. Arnel Borja (medical examiner).
- The defense, represented by Virgilio and Flora Romero, denied the allegations, claiming Marilou was lying due to family conflicts.
- The trial court found Romero guilty beyond reasonable doubt, leading to an automatic review by the Supreme Court.
Issue:
- (Unlock)
Ruling:
- The Supreme Court affirmed the credibility of the prosecution witnesses, supporting the trial court's findings.
- The Court determined that the rape was not qualified, as the information did not alleg...(Unlock)
Ratio:
- The Supreme Court noted that minor inconsistencies in witness testimonies do not necessarily undermine credibility.
- The trial judge is best positioned to assess witness demeanor and credibility; Marilou's and other witnesses' testimonies were found consistent on essential facts.
- Delays in reporting the crime are common among young victims and do not automatically suggest fabrication.
- For the death penalty under Article 335, the in...continue reading
Case Digest (G.R. No. 137037-38)
Facts:
The case involves Virgilio Romero, the accused-appellant, who was found guilty of two counts of rape against his step-granddaughter, Marilou Romero. The incidents occurred in April 1996 in Barangay Apad, Polangui, Albay, Philippines. The Regional Trial Court of Ligao, Albay, Branch 13, rendered its decision on December 17, 1998, sentencing Romero to death for each count of rape under Article 335 of the Revised Penal Code, as amended by Republic Act No. 7659. The prosecution's case was based on two separate informations filed on September 12, 1997, alleging that Romero had carnal knowledge of Marilou against her will. The first incident was reported to have occurred at around 10:00 AM, and the second at 1:00 PM on the same day.
Marilou, who was 15 years old at the time of the trial, testified that she had been living with Romero and his common-law wife, Flora, since she was one year old. She recounted that the first rape occurred when she was ten years old in Batangas, and the subsequent rapes happened in Polangui when she was thirteen. The prosecution presented several witnesses, including Rodolfo Sameniano, the barangay chairman, and Dr. Arnel Borja, who conducted a medical examination on Marilou. The defense, on the other hand, presented Virgilio Romero and Flora Romero, who denied the allegations and claimed that Marilou was lying due to familial conflicts. The t...