G.R. No. L-14214 - Velasco vs. Republic

Accused-appellant Noel Sandoval was charged in seven separate Informations for acts of rape:

Five counts of rape involving Teresa Micu, then thirteen (13) years old.
Two counts of statutory rape involving Victoria “Rhea” Micu, then eleven (11) years old, as evidenced by her Birth Certificate.

Each Information alleged that the accused used force, threat, and intimidation to have sexual intercourse with the complainants against their will, causing damage and prejudice.

The Informations were filed before the Regional Trial Court of Dagupan, Pangasinan, Branch 42, covering incidents that occurred on or about various dates in 1995 and 1997 at barangay Casibong, San Jacinto, Pangasinan.
Accused-appellant was arraigned on July 23, 1997 for the first five counts of rape, to which he pleaded NOT GUILTY.
A Motion for Leave to Amend was filed by the Public Prosecutor to allege the relationship between the accused and the victims, but the defense objected on the ground that such amendment would prejudice the accused’s rights.
Accused-appellant later appeared and pleaded NOT GUILTY to the two counts of statutory rape on August 7, 1997.

Testimonies included detailed accounts from Teresa Micu on the incidents of rape, wherein she outlined the events clearly across multiple occasions.
The medical testimony provided by Dr. Luisa Cayabyab for Rhea Micu was inconclusive regarding the presence or absence of force, though it did not exclude the possibility of rape.
Rhea Micu’s own testimony was straightforward and convincing, detailing the occurrences in the household of her stepfather, thereby strongly implicating the accused.

Accused-appellant was found guilty beyond reasonable doubt on six counts of rape and was sentenced to suffer the mandatory penalty of DEATH for each count.
He was acquitted on one count (Criminal Case No. 97-01818-D) for insufficiency of evidence.

The accused contended that the trial court erred by convicting him for the rape of Teresa Micu and imposing the death penalty despite the fact that he was not legally married to the victim’s mother.
He argued that there was an error in convicting him for rape over Rhea Micu based on testimonial credibility, compounded by the inconclusive medical findings.
The accused also challenged the award of moral and exemplary damages, asserting that such damages were based on the testimony of an aunt rather than a legal guardian or the complainants themselves.

Whether the trial court erred in convicting the accused-appellant for the rape of Teresa Micu based solely on her testimony and subsequently imposing the death penalty.
Whether the trial court committed error in convicting him for the rape of Rhea Micu, particularly in view of the inconclusive medical evidence and questions raised regarding her credibility.
Whether the amendment of the Informations to allege the accused’s relationship to the victims (which later exposed him to a higher penalty) was procedurally improper after he had already pleaded NOT GUILTY.
Whether the award of moral and exemplary damages to the complainants was proper despite their non-testimony on this matter and reliance on the evidence of a non-legal guardian.