Title
People vs. XXX64352
Case
G.R. No. 264352
Decision Date
Dec 4, 2023
The Supreme Court affirmed the conviction of accused-appellant for rape based on the victim's credible testimony corroborated by medical findings, modifying damages awarded to a senior victim.

Case Digest (G.R. No. 205604)
Expanded Legal Reasoning Model

Facts:

  • The Charge and Trial
    • The accused-appellant, XXX264352, was charged by Information dated February 28, 2017 with rape under Article 266-A(1) in relation to Article 266-B of the Revised Penal Code, as amended.
    • The incident was alleged to have occurred on or about December 10, 2016, at 10:30 p.m., in the City of xxxxxxxxxxx, Philippines.
    • The accused was alleged to have, by force, threat and/or intimidation, willfully, unlawfully, and feloniously had carnal knowledge of the complainant, AAA264352, against her will and without her consent.
    • On arraignment, the accused pleaded not guilty.
    • Trial ensued.
  • Prosecution’s Evidence
    • The complainant, AAA264352, testified that at about 10:30 p.m. on December 10, 2016, while she was sleeping, the accused, her brother-in-law, suddenly entered her house.
    • She was alarmed and grabbed a bolo (a large knife) as the accused approached her, held both her hands, and pushed her against a wall.
    • She attempted to strike the accused with her bolo but missed; the accused twisted her hand causing the bolo to fall.
    • The accused then pushed her, forcibly laid her on a bed, pulled her duster up, forcibly pulled her legs apart, laid on top of her, and inserted his penis in her vagina.
    • After the act, the accused stood up, put on his clothes, and warned her not to close the door as he would come back.
    • CCC264352, the complainant’s daughter, testified that she was awakened by her younger sister’s report of their mother groaning in pain and found the complainant crying and in pain.
    • The complainant then informed her daughter that she was raped by the accused.
    • They immediately reported the incident to the police.
    • Dr. Medardo S. Estanda conducted the medical and physical examination on December 12, 2016, and found spermatozoa in the complainant’s vagina, which was compatible with previous sexual intercourse.
  • Defense’s Evidence
    • The accused denied committing the crime.
    • He testified that on the night in question, he was at a cockpit in xxxxxxxxxxx from 10:30 p.m. to 4:00 a.m., thus could not have committed the crime.
  • Trial Court’s Decision
    • The Regional Trial Court, Branch 55, xxxxxxxxxxx Negros Occidental, ruled on May 16, 2018, finding the accused guilty beyond reasonable doubt of rape and sentenced him to reclusion perpetua.
    • The court ordered payment of civil indemnity, moral damages, and exemplary damages amounting to PHP 100,000.00 each, with six percent interest per annum from finality until full payment.
    • The court gave full credence to the complainant’s testimony and rejected the accused’s denial.
  • Court of Appeals Proceedings
    • On appeal, the accused raised the alleged inconsistencies and incredibility of the complainant’s testimony.
    • The accused also argued that the medical findings disproved sexual intercourse due to the absence of lacerations or tears.
    • He additionally claimed that any sexual act was consensual.
    • The Office of the Solicitor General argued the prosecution’s proof was beyond reasonable doubt and that the victim’s testimony was corroborated by medical evidence.
    • On June 29, 2022, the Court of Appeals affirmed the conviction but modified the amount of damages awarded to PHP 75,000.00 each for civil indemnity, moral damages, and exemplary damages.
  • Present Appeal
    • The accused-appellant elevated the case to the Supreme Court, seeking acquittal.
    • Both parties adopted their Court of Appeals briefs.

Issues:

  • Whether or not the accused-appellant is guilty beyond reasonable doubt of the crime of rape under Article 266-A(1) in relation to Article 266-B of the Revised Penal Code.
  • Whether the complainant’s testimony and the medical findings sufficiently establish carnal knowledge through force, threat or intimidation.
  • Whether the accused-appellant’s alibi and denial create reasonable doubt to warrant acquittal.
  • Proper amount of damages and penalties to be awarded to the victim.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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