Title
People vs. XXX
Case
G.R. No. 233867
Decision Date
Feb 28, 2022
Accused convicted of multiple counts of rape and lascivious conduct against a minor; court upheld victim's credible testimony and medical evidence, imposing reclusion perpetua and monetary damages.
A

Case Digest (G.R. No. 233867)

Facts:

  • Parties and Procedural Posture
    • Plaintiff-Appellee: People of the Philippines; Accused-Appellant: XXX.
    • Charged with two counts of rape through sexual assault (Art. 266-A(2), RPC, as amended by RA 8353, in relation to RA 7610) and one count of rape through sexual intercourse (Art. 266-A(1), RPC, as amended, in relation to RA 7610) in Criminal Case Nos. 06-809, 07-146, and 07-147.
    • RTC Branch 207 consolidated the cases and, in a Joint Decision dated November 5, 2014, found appellant guilty beyond reasonable doubt.
    • CA affirmed with modification of damages and fines in its Decision of March 30, 2017 (CA-G.R. CR-H.C. No. 07147).
  • Underlying Incidents and Testimonies
    • Victim AAA, aged 14, alleged three assaults by appellant between August 23 and September 2, 2006, each in AAA’s bedroom in xxxxxxxxxxx City.
      • August 23 (Case 07-146): appellant entered at ~2 a.m., covered AAA’s mouth, kissed and molested her breasts, inserted finger into her vagina, then threatened her.
      • August 26 (Case 07-147): appellant again covered AAA’s mouth, removed her clothing, had penile intercourse for 5–10 minutes, threatened her thereafter.
      • September 2 (Case 06-809): appellant locked the door, kissed AAA, mashed her breasts, inserted his finger into her vagina; discovered by nursemaid CCC.
    • Medico-legal examination by PSI Ebdane revealed deep healed lacerations at 5 and 7 o’clock positions on the hymen.
  • Defense Version and Lower Court Rulings
    • Appellant denied all charges, claiming alibi for first two incidents and benign medical check for the third.
    • RTC credited AAA’s and CCC’s testimonies, disbelieved appellant’s denial, and found all elements of the offenses proven.
    • CA upheld the convictions, emphasizing that sole credible testimony of victim and medico-legal findings sufficed; modified indemnities and fines.

Issues:

  • Whether appellant’s conviction for two counts of rape through sexual assault and one count of rape through sexual intercourse is proper.
  • Whether the nomenclature of offenses and the penalties and damages imposed conform to applicable laws (RPC Art. 266-A, RA 8353, RA 7610, and related jurisprudence).

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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