Case Digest (G.R. No. 227363) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines v. Salvador Tulagan (G.R. No. 227363, March 12, 2019), accused-appellant Salvador Tulagan, a neighbor of AAA’s grandmother in San Carlos City, was charged with two separate offenses against AAA, a nine-year-old girl. In Criminal Case No. SCC-6210, he was accused of sexual assault by forcefully inserting his finger into AAA’s vagina in September 2011. In Criminal Case No. SCC-6211, he was accused of statutory rape for having sexual intercourse with the same victim on October 8, 2011. AAA’s aunt, BBB, witnessed AAA’s distressed condition, observed swelling of her genitalia, and elicited a confession naming Tulagan. Medical examination revealed hymenal laceration and dilated vaginal opening. At trial, Tulagan denied the charges and claimed an alibi, but the Regional Trial Court of San Carlos City found him guilty on both counts, relying on AAA’s credible testimony and medical evidence. He was sentenced to reclusion perpetua for statutory rape and to an Case Digest (G.R. No. 227363) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Information and preliminary trial
- Accused-appellant Salvador Tulagan was charged in two Informations before the RTC of San Carlos City:
- Criminal Case No. SCC-6210: Sexual assault (Article 266-A(2), RPC, in relation to R.A. 7610).
- Criminal Case No. SCC-6211: Statutory rape (Article 266-A(1)(d), RPC, in relation to R.A. 7610).
- AAA’s testimony and medical findings
- AAA testified to both incidents, identifying Tulagan by name, and described pain and crying during the acts.
- Medical examination revealed a healed laceration of the hymen and dilated vaginal opening consistent with forced penetration.
- Defense and lower court decisions
- Tulagan alleged alibi: he was gathering banana leaves, never near AAA’s house.
- RTC convicted him of both crimes based on AAA’s credible testimony and medical evidence and sentenced him to reclusion perpetua plus indemnities.
- The Court of Appeals affirmed with modifications, increasing some damages and adjusting penalties.
- Appeal to the Supreme Court
- Tulagan argued that AAA’s testimony was inconsistent, lacked credibility, and that guilt was not proven beyond reasonable doubt.
- He also challenged the application of R.A. 7610 and the classification of the offenses and penalties.
Issues:
- Did the appellate courts err in finding AAA’s testimony credible despite alleged minor inconsistencies and in upholding Tulagan’s conviction beyond reasonable doubt?
- What are the proper legal classifications and penalties for the crimes of sexual assault and statutory rape committed against a minor, in relation to the Revised Penal Code (as amended by R.A. 8353) and R.A. 7610?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)