Title
People vs. Villanueva
Case
G.R. No. 138364
Decision Date
Oct 15, 2003
A father convicted of raping his daughter; Supreme Court affirmed guilt but reduced penalty to life imprisonment due to insufficient proof of victim's minority.
A

Case Digest (G.R. No. 138364)

Facts:

  • Family Background and Poverty:
    • AAA, the victim, is the eldest of nine children in the Villanueva family.
    • The family lived in extreme poverty, with appellant Rogelio Villanueva working as a fisherman and his wife Estelita working as a laundrywoman-househelper in Davao City to support the family.
  • Incident on 12 December 1996:
    • After lunch, appellant sent his daughters to do laundry but instructed AAA to stay behind.
    • Appellant dragged AAA from the kitchen to the living room, poked a knife at her, and forced her to remove her panty.
    • When AAA resisted, appellant struck her with an iron bar and punched her in the abdomen, rendering her unconscious.
    • Upon regaining consciousness, AAA felt pain in her genitalia, which was bleeding.
  • Previous Sexual Assaults:
    • AAA revealed that her father had molested her several times in the past.
    • Appellant also attempted to sexually abuse his younger daughter, Mary Joy, who fled to her aunt’s house and later informed her mother, Estelita, about the abuse.
  • Reporting the Crime:
    • On 17 February 1997, AAA, accompanied by her mother and sister, reported the rape to the Sta. Cruz Municipal Police Station.
    • AAA and Estelita executed sworn statements, and AAA underwent a medical examination, which revealed healed lacerations on her hymen.
  • Appellant’s Defense:
    • Appellant denied the allegations, claiming he was working on a farm during the time of the alleged rape.
    • He accused Estelita of instigating the rape charge to prevent him from filing abandonment charges against her.

Issues:

  • Whether the trial court erred in finding appellant guilty beyond reasonable doubt of rape under Article 335 of the Revised Penal Code, as amended by RA 7659.
  • Whether the trial court erred in imposing the death penalty on appellant.
  • Whether the Information sufficiently alleged the qualifying circumstances of minority and relationship to warrant the imposition of the death penalty.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

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