Case Digest (G.R. No. 219963)
Facts:
People of the Philippines v. Ricardo Tanglao y Egana, G.R. No. 219963, June 13, 2018, the Supreme Court Third Division, Martires, J., writing for the Court.The criminal information charged Ricardo Tanglao y Egana (accused-appellant) with rape under Art. 266‑A(1)(d) of R.A. No. 8353 in relation to R.A. No. 7610, alleging that on or about 14 September 2001 he had carnal knowledge of his then seven‑year‑old daughter AAA. At arraignment the accused pleaded not guilty and trial ensued.
Prosecution witnesses included AAA, her mother BBB, her brother DDD, Dr. Irene Baluyot (PGH‑CPU pediatrician) and Dr. Cynthia Leynes (PGH psychology consultant). AAA testified that on the night of 14 September 2001 her father lied between her and DDD on a double‑deck bed, covered her mouth, kissed her lips and neck and inserted his penis into her vagina; DDD corroborated hearing his sister whimper, seeing the bed shake and observing movements of the accused. The next day AAA’s bloodied underwear was noticed, she reported the incident to her mother and to barangay/police authorities, and she was referred to the NBI and the Philippine General Hospital for medico‑legal and psychiatric examinations. Dr. Baluyot’s findings were “suggestive of blunt force or penetrating trauma,” and Dr. Leynes’ psychiatric evaluation diagnosed sexual abuse.
At the Regional Trial Court (RTC), XXX City, the trial court found the accused guilty beyond reasonable doubt of rape under Art. 266‑A(1)(d), sentenced him to reclusion perpetua, and awarded P50,000 civil indemnity, P50,000 moral damages and P25,000 exemplary damages (RTC Decision, 6 January 2012). The accused appealed to the Court of Appeals (CA).
The Court of Appeals, Special Tenth Division, in a 15 September 2014 Decision (CA‑G.R. CR. HC No. 05567) denied the appeal for lack of merit, affirmed the conviction and penalty but modified the damages to P75,000 civil indemnity, P75,000 moral damages and P3...(Subscriber-Only)
Issues:
- Did the trial court gravely err in giving credence to the complainant’s testimony?
- Did the trial court gravely err in finding the accused guilty beyond reasonable doubt of rape under A...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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