Title
People vs. Villacampa y Cadiente
Case
G.R. No. 216057
Decision Date
Jan 8, 2018
Ceferino Villacampa convicted of multiple counts of rape, acts of lasciviousness against four minor siblings; affirmed by Supreme Court with modified penalties and civil liabilities.

Case Digest (G.R. No. 216057)
Expanded Legal Reasoning Model

Facts:

  • Consolidation and Nature of Cases
    • This case involves 12 consolidated criminal cases filed against appellant Ceferino Villacampa y Cadiente, popularly known as "Daddy Gaga."
    • The charges include eleven counts of rape and one count of acts of lasciviousness, specifically in relation to Republic Act No. 7610, which provides special protection to children against abuse, exploitation, and discrimination.
    • The incident reports and proceedings were consolidated under FC Criminal Case Nos. 1359–1370, with the various cases addressing different aspects of the offenses.
  • Chronology of the Offenses
    • Incidents occurred in March 2006 involving four minor sibling victims – identified as AAA, BBB, CCC, and DDD – aged 11, 6, 14, and 13 respectively at the time of the incidents.
    • Detailed accounts for each victim are as follows:
      • AAA (11 years old)
        • On 21 March 2006, while on her way to the kitchen, AAA was called by Villacampa, who then removed her shorts, laid her down, and inserted his finger into her vagina; he attempted to penetrate her with his penis but was interrupted by the timely knock of her mother and sister.
ii. On 23 March 2006, while preparing for school, Villacampa made her lie on the papag and repeated the misconduct by removing her shorts and underwear, inserting his finger, and licking her vagina. iii. On 25 March 2006, when AAA was left in charge of her siblings, he again removed her clothing, inserted his finger into her genital area, and licked her, causing her pain before sending her out to play. iv. AAA eventually disclosed the incidents to her mother and confided in her father.
  • BBB (6 years old)
    • Testified that on several occasions, while alone in the house, Villacampa inserted his finger into her vagina, causing her pain.
ii. The abuse occurred when she was playing, eating, and even while sleeping. iii. For the last incident, Villacampa threatened to kill her mother if she reported the abuse; BBB later recounted the incident to her older sister, AAA.
  • CCC (14 years old)
    • On 21 March 2006, while CCC was on the papag in her room, Villacampa entered her room, threatened to kill her father, kissed her on the lips, and inserted his finger into her vagina.
ii. Although the Information in one of the cases stated that Villacampa merely touched her and kissed her lips, face, and neck, her testimony revealed the act of insertion. iii. On 25 March 2006, after a drinking spree involving CCC’s mother, Villacampa forced CCC to drink alcohol; later that evening, he undressed her, kissed her, and forcibly inserted his penis into her vagina, an act which led to her subsequent pregnancy.
  • DDD (13 years old)
    • On 25 March 2006, while DDD was asleep in the living room with her sister, Villacampa awoke her, covered her mouth, removed her shorts and underwear, and inserted his penis into her vagina.
ii. He threatened her not to alert her family, warning that he would kill her father if she reported the incident. iii. The next morning, DDD eventually reported the incident to her mother, though initial disbelief ensued.
  • Medical and Witness Evidence
    • All four victims underwent medico-legal examinations assisted by their father and their aunt, MMM.
    • AAA and CCC were examined by Dr. Mariglo Grace Chincuango, whose findings included shallow and deep healed lacerations on the hymen at various clock positions.
    • BBB and DDD were examined by Dr. Lorelei Guevarra, with the medical records verified by an administrative officer from JBL Hospital.
    • The consistency of the victims’ testimonies, along with the medical evidence, strongly corroborated the allegations of sexual abuse.
  • Testimonies and Defense Arguments
    • The testimonies of the victims were detailed and consistent, with each providing specific descriptions of the abuse.
    • Villacampa, for his defense, argued that the victims’ testimonies were not credible, contending that the reports were orchestrated by the victims’ father and Aunt MMM.
    • Additionally, for victim CCC, Villacampa claimed there was a consensual relationship, further alleging that he had courted her and fathered her child.
    • The lower courts, however, found these defenses insufficient to overcome the presumption of innocence, ultimately convicting him in most of the counts.
  • Procedural History
    • The Regional Trial Court (RTC) rendered a decision on 28 March 2011, finding Villacampa guilty beyond reasonable doubt on multiple counts, including rape through sexual assault, simple rape, and acts of lasciviousness.
    • Villacampa was acquitted only in FC Criminal Case No. 1370 due to inconsistencies and doubts in DDD’s testimony.
    • The Court of Appeals (CA) subsequently affirmed the RTC’s decision with certain modifications in the penalties imposed.
    • Villacampa filed a Notice of Appeal on 8 April 2014, challenging the convictions and sentences.

Issues:

  • Determination of Guilt under the Relevant Statutes
    • Whether the evidence presented established beyond reasonable doubt that Villacampa committed the acts of rape through sexual assault, simple rape, and lascivious conduct as charged.
    • Whether the acts of inserting his finger and, in one instance, his penis, constituted rape and lascivious conduct under the provisions of the Revised Penal Code and RA 7610.
  • Credibility and Relevance of Victims’ Testimonies
    • Whether the testimonies of the minor victims, despite alleged external influences, were sufficiently credible.
    • Whether any discrepancies in the victims’ descriptions, particularly in DDD’s account, warranted an acquittal on any of the charges.
  • Application of the Appropriate Penal Provisions and Penalties
    • Whether the lower courts correctly applied Article 266-A of the Revised Penal Code, as amended, in determining the crime of rape through sexual assault.
    • Whether for offenses committed against children under 12 years of age, the proper penalty should be based on the guidelines set forth in RA 7610, specifically concerning the penalty of reclusion temporal in its medium period.
    • Whether moral ascendancy and the use of force or intimidation, as exhibited through the defendant’s relationship with the victims, satisfy the elements of the charged crimes.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)
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