Case Digest (G.R. No. 211026)
Facts:
In the case People of the Philippines vs. Renato B. Suedad (G.R. No. 211026, June 8, 2016), appellant Renato B. Suedad was charged with four counts of qualified rape involving his minor daughter, herein referred to as AAA to protect her identity. The incidents occurred between October 20, 2008, and March 20, 2009, in their respective residences in Sultan Kudarat Province. AAA was eleven years old at the time of the offenses. Her mother, BBB, had to work abroad when AAA was less than two years old, leaving the appellant as her primary caregiver. AAA testified in detail regarding the sexual abuses committed by her father on three separate occasions while also identifying the accused as her assailant. The prosecution presented testimony from AAA, her mother, maternal relatives, and a medical professional, Dr. Raul Manansala, who conducted a medico-legal examination that confirmed physical evidence consistent with sexual abuse. The accused admitted physical intimacy with AAA but de
Case Digest (G.R. No. 211026)
Facts:
- Background Information
- Renato B. Suedad (appellant) was charged with four (4) counts of qualified rape involving his daughter, AAA, an eleven-year-old child born on July 5, 1997.
- AAA’s mother, BBB, had to work overseas when AAA was less than two years old, leaving AAA in the care of appellant. BBB returned home only occasionally.
- Details of the Alleged Crimes
- The first rape allegedly occurred on October 20, 2008, at about 5:00 PM in their house at Isulan, Sultan Kudarat.
- The second incident took place during the last week of October 2008 at their house in Bagumbayan, Sultan Kudarat.
- The third occurrence was on November 26, 2008, at about 11:00 PM during the wake of appellant's mother (AAA’s grandmother) held at the grandmother's house in Bagumbayan.
- The fourth act was committed on March 20, 2009, at around 9:00 AM at their house in Bagumbayan.
- Proceedings in Lower Courts
- Appellant pleaded not guilty.
- At the pre-trial conference, the birth date of AAA and the biological relationship to appellant were stipulated.
- Prosecution witnesses included AAA, her mother BBB, maternal grandmother CCC, maternal aunt DDD, and Municipal Health Officer Dr. Raul Manansala.
- AAA recounted the acts of sexual abuse in detail, including the use of force such as choking during the November 2008 incident.
- AAA disclosed the abuse to her grandmother CCC on April 15, 2009, and was medically examined on April 16, 2009, by Dr. Manansala.
- Medical findings showed a partially healed laceration on AAA’s hymen. The doctor explained that frequent sexual contact in a child with a thick, elastic hymen could cause such lacerations.
- Appellant admitted to having been physically intimate with AAA but denied rape, claiming ill motives behind the charges, including a supposed grudge held by AAA over a discovered love letter and family quarrels with CCC.
- The defense presented alibi witnesses for certain dates.
- Lower Court Decisions
- The Regional Trial Court (RTC) found appellant guilty beyond reasonable doubt on three counts (October 20, November 26, and March 20, 2009) and acquitted him on the count regarding the last week of October 2008.
- Appellant was sentenced to reclusion perpetua and ordered to pay indemnity and moral damages.
- The Court of Appeals affirmed the RTC's decision with modification, enhancing damages and emphasizing that appellant was sentenced to reclusion perpetua without eligibility for parole for each count.
- Appeal to the Supreme Court
- Appellant filed an appeal.
- Supplemental briefs were invited but not filed by either party.
- The Supreme Court rendered its decision on June 8, 2016.
Issues:
- Whether appellant Renato B. Suedad is guilty beyond reasonable doubt of three counts of qualified rape committed against his daughter, AAA.
- Whether the trial and appellate courts correctly applied the law on rape and the credibility of the victim’s testimony.
- Proper penalty and awards of damages to be imposed on the appellant.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)