Case Digest (G.R. No. L-46095)
Facts:
The case of People of the Philippines vs. Camilo Soriano (G.R. Nos. 142779-95, August 29, 2002) arose from accusations of repeated and brutal statutory rape and sexual assault committed by the accused, Camilo Soriano, against his 11-year-old daughter, Maricel Soriano. The incidents allegedly took place in Baguio City, between October 14 and October 29, 1998. Four separate Informations charged Soriano with statutory rape through sexual intercourse on four occasions, while thirteen additional Informations charged him with rape through sexual assault, specifically the insertion of a finger into the victim’s vagina, on thirteen different dates within the said period.
Soriano initially denied the charges and pleaded not guilty. The victim, Maricel, testified in detail regarding the multiple instances of abuse, describing the circumstances in their cramped, shared family quarters. She testified how her father forcibly kissed, undressed, and sexually assaulted her while her siblings w
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Case Digest (G.R. No. L-46095)
Facts:
- Nature of the Case and Charges
- Camilo Soriano was charged with multiple counts of statutory rape through sexual intercourse and rape through sexual assault involving his 11-year-old daughter Maricel Soriano.
- Four Informations for statutory rape through sexual intercourse were filed for incidents on 15 October 1998, 28 October 1998, and twice on 29 October 1998.
- Thirteen Informations for rape through sexual assault (insertion of finger into vagina) were filed for incidents on 14, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25, 26, and 27 October 1998.
- Soriano pled not guilty to all charges upon arraignment.
- Family Background and Living Situation
- Leonora Espino separated from her first husband in 1982 and started living with Camilo Soriano in 1984; whether they were married was unclear although the birth certificate of Maricel indicated their marriage.
- Leonora and Camilo had eight children; four survived including Maricel (born 22 February 1987).
- Camilo was imprisoned in December 1991 for murder and incarcerated until May 1998. He reunited with family in cramped quarters in Baguio City upon release, living with Leonora, their children, and boarders in a small house.
- Leonora often worked outside home while Camilo stayed mostly indoors, sometimes with alcohol intoxication and violent conduct.
- Occurrence of the Crimes and Reporting
- On 14 October 1998, Leonora went to La Union, leaving the children at home with Camilo. This period allowed Camilo privacy to commit the assaults.
- Maricel was repeatedly raped and sexually assaulted by her father during 14 to 29 October 1998. On four occasions, Camilo forced penile penetration; on thirteen occasions, digital penetration occurred.
- Maricel’s elder brother Michael and siblings witnessed or became aware of the abuse and informed their mother.
- Following a family quarrel and Leonora’s absence, Maricel was secretly taken to the barangay captain and later to authorities for interview and examination. Camilo was apprehended immediately.
- Trial Testimonies
- Maricel gave candid, consistent, and detailed accounts of the sexual abuses perpetrated by her father, including dates, acts of penetration, and the setting (cramped one-room house with a double-deck bed).
- Michael Soriano testified as corroborative witness, stating he had seen his father assault Maricel.
- Medical examination by a medico-legal officer confirmed recent loss of virginity and signs consistent with sexual abuse.
- Camilo Soriano denied the charges, claiming the accusations stemmed from Leonora’s alleged jealousy and desire to separate. He produced a letter allegedly from Leonora’s lover to support his claim.
- Soriano also raised alibi defenses and disputed the timing and feasibility of the acts given the circumstances in the house.
- Trial Court Decision
- The Regional Trial Court of Baguio City found Camilo Soriano guilty beyond reasonable doubt of the four counts of statutory rape through sexual intercourse and thirteen counts (twelve proven) of rape through sexual assault.
- He was sentenced to death for each of the four counts involving penetration and imprisonment under the Indeterminate Sentence Law for the rape through sexual assault counts.
- Civil indemnities and damages were awarded to the victim.
- Appeal and Supreme Court Review
- Upon automatic review, Soriano argued the insufficiency of evidence, alleged inconsistencies, improbable circumstances, and motivations for false accusations.
- The Supreme Court considered the victim’s credible testimony, corroborating evidence, and medical findings.
Issues:
- Whether Camilo Soriano is guilty beyond reasonable doubt of the charges of rape through sexual intercourse and rape through sexual assault against his daughter.
- Whether the testimony of the victim, supported by physical and circumstantial evidence, is credible and sufficient to establish the guilt of the accused.
- Whether the defense of denial, alibi, and claims of improbable circumstances and ulterior motives can overcome the prosecution’s evidence.
- The proper penalties and damages to be imposed in accordance with applicable law, including the constitutionality of the death penalty.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)