Case Digest (G.R. No. 225781)
Facts:
In the case of People of the Philippines vs. XXX, G.R. No. 225781, the accused-appellant, XXX, faced charges of Rape and Attempted Rape as per the Revised Penal Code and related legislation. The events transpired in Nueva Ecija, with the alleged crimes occurring on December 25, 2005, and January 5, 2006. The first incident involved AAA, a 14-year-old minor, where the accused allegedly threatened her with a bladed weapon before committing the act of rape. This included detailed accounts where the accused stripped the victim of her clothing and forcibly had sexual intercourse with her against her will. The second incident did not culminate in consummated Rape due to an interruption. The accused-appellant entered a not-guilty plea during arraignment.In the trial, the prosecution presented witnesses including the victim, her mother, and a medical doctor, while the defense solely relied on the accused's testimony. Notably, the victim later executed an affidavit of desistance,
Case Digest (G.R. No. 225781)
Facts:
- Chronology of the Crimes
- The accused-appellant was charged in two distinct criminal cases:
- Criminal Case No. 692-06-P for the crime of rape committed on December 25, 2005.
- Criminal Case No. 691-06-P for the crime of attempted rape committed on January 5, 2006.
- On December 25, 2005, at approximately 8:00 p.m., the accused allegedly used a bladed weapon to force himself upon the minor victim, AAA, aged 14, at a location in Nueva Ecija.
- The prosecution alleged that he removed the victim’s clothes, rendered her naked, and, by means of force and intimidation, had carnal knowledge of her.
- The incident was detailed as having taken place in the residence or nearby area where familial relations were implicated, with aggravating circumstances including the use of a weapon and occurrence during nighttime.
- On January 5, 2006, the incident of attempted rape is described:
- Occurred at around 11:00 a.m. at another location in Nueva Ecija, where the accused used a kitchen knife to intimidate the victim.
- He allegedly forced the victim onto a wooden bed, removed parts of her clothing, and initiated the commission of rape, which was interrupted by the arrival of BBB, the victim’s mother, who intervened by physically assaulting the accused.
- Testimonies and Evidence
- The prosecution presented multiple witnesses, including:
- The victim AAA, who gave a detailed account of the sexual assault through direct testimony.
- BBB, the victim’s mother, who provided corroborative narrative regarding the events and her confrontation with the accused.
- Dr. Ma. Eilyn F. Basco, whose medical examination on January 8, 2006 established physical evidence (contusions, lacerations, and bleeding) corroborating the victim’s account.
- Despite the detailed testimony, the victim later executed a Sinumpaang Salaysay ng Pag-uurong ng Habla dated November 26, 2013, wherein she recanted her earlier allegations and blamed personal conflicts for the incident.
- The recantation was further confirmed when she testified on November 28, 2013 in support of the defense.
- The defense testified that the accused was in a different location at the time of the incident and pointed to the recantation as evidence for his innocence.
- Proceedings and Judicial Findings
- The Regional Trial Court (RTC) issued a January 21, 2014 Joint Decision:
- Acquitting the accused-Appellant in Criminal Case No. 691-06-P (attempted rape).
- Convicting him in Criminal Case No. 692-06-P for the crime of rape, sentencing him to reclusion perpetua along with ordering payment of civil indemnity and moral damages initially set at P50,000.00 each.
- The Court of Appeals reaffirmed the RTC decision on September 24, 2015, emphasizing:
- The unreliability of recantations in rape cases due to potential ulterior motives such as coercion or monetary influence.
- The consistency and detail of the victim’s original testimony despite the later recantation.
- Appellate proceedings focused on whether the evidence, particularly the original detailed testimony and corroborative medical findings, sufficed to establish guilt beyond reasonable doubt despite the victim’s recantation.
- Contextual and Statutory Background
- The offenses charged were anchored on the provisions of:
- Article 266-A of the Revised Penal Code (RPC) for the crime of rape.
- Article 266-B of the RPC for prescribing the corresponding penalty of reclusion perpetua.
- The Information erroneously correlated the offense with Republic Act No. 7610; however, the appellate decision rectified the proper legal basis to be solely under the Revised Penal Code.
- Additional penalty modifications involved increasing the award for civil indemnity, moral damages, and exemplary damages from P50,000.00 to P75,000.00 each, with legal interest accruing at 6% per annum.
Issues:
- Sufficiency of the Prosecution’s Evidence
- Whether the cumulative evidence presented—consisting of the victim’s initial, detailed testimony, medical examination reports, and corroborative witness accounts—established the accused-appellant’s guilt beyond reasonable doubt for the crime of rape.
- The legal effect of the victim’s subsequent recantation on the credibility and reliability of her initial testimony.
- Proper Classification of the Crime
- Whether the accused should be charged and convicted strictly under Article 266-A, Paragraph 1(a) in relation to Article 266-B of the RPC, thereby deleting the incorrect correlation to Republic Act No. 7610.
- The Evaluation of Recantation
- How the court should treat the recantation based on standards established in previous case law, considering the time lapse between the original testimony and the recantation.
- Whether the evidentiary and testimonial inconsistencies, if any, affect the overall credibility of the victim’s account.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)