Title
People vs. Teodoro y Vallejo
Case
G.R. No. 172372
Decision Date
Dec 4, 2009
Appellant convicted of two counts of statutory rape against a minor; Supreme Court upheld reclusion perpetua, citing credible victim testimony and medical evidence, and awarded damages.

Case Digest (G.R. No. 172372)
Expanded Legal Reasoning Model

Facts:

# Background and Charges

  • The appellant, Romar Teodoro y Vallejo, was charged with three counts of rape under separate Informations:
    • Criminal Case No. 8538: Rape allegedly committed on June 18, 1995, in Barangay Pook ni Banal, San Pascual, Batangas. The victim, AAA, was below 12 years old.
    • Criminal Case No. 8539: Rape allegedly committed during the first week of July 1995, in the same location. AAA was still below 12 years old.
    • Criminal Case No. 8540: Rape allegedly committed on March 30, 1996, in the same location. AAA was 12 years old at the time.

# Prosecution’s Evidence

  • Medical Evidence: Dr. Rosalina Caraan-Mendoza testified that AAA had healed lacerations and sperm cells were found in her vaginal smear, indicating previous sexual intercourse.
  • AAA’s Testimony: AAA, born on July 21, 1983, testified that the appellant raped her on June 18, 1995, and during the first week of July 1995. She described the incidents in detail, including the use of force and threats. She also testified about a third incident on March 30, 1996, which was witnessed by her brother.
  • Defense’s Claim: The appellant denied the first two rapes but admitted to consensual sexual intercourse with AAA on March 30, 1996, claiming they were in a romantic relationship.

# Trial Court Decision

  • The Regional Trial Court (RTC) convicted the appellant of two counts of statutory rape (Criminal Case Nos. 8538 and 8539) and sentenced him to reclusion perpetua for each count. He was acquitted in Criminal Case No. 8540.

# Court of Appeals Decision

  • The Court of Appeals (CA) affirmed the RTC’s decision, dismissing the appellant’s argument that the Information in Criminal Case No. 8539 was vague due to the lack of an exact date.

Issues:

  • Whether the prosecution proved the appellant’s guilt beyond reasonable doubt for the two counts of statutory rape.
  • Whether the Information in Criminal Case No. 8539 was defective for failing to state the exact date of the crime.
  • Whether the lower courts erred in convicting the appellant based on AAA’s testimony.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Conclusion:

  • The Supreme Court affirmed the appellant’s conviction for two counts of statutory rape, upheld the penalty of reclusion perpetua, and modified the damages awarded to the victim. The Court emphasized the credibility of the victim’s testimony and the sufficiency of the prosecution’s evidence in proving the appellant’s guilt beyond reasonable doubt.

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