Case Digest (G.R. No. 205604) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
The case involves accused-appellant XXX264352, charged on February 28, 2017, with the crime of rape under Article 266-A(1) in relation to Article 266-B of the Revised Penal Code. The incident allegedly occurred on December 10, 2016, in the City of xxxxxxxxxxx, Philippines. The complainant, AAA264352, a 69-year-old woman, testified that the accused, her brother-in-law, forcibly entered her home at around 10:30 p.m., restrained her hands, pushed her against the wall, wrested away her bolo (machete), and violently raped her by forcibly laying her on the bed, pulling her legs apart, and penetrating her without her consent. Her daughter, CCC264352, corroborated her mother's distress and immediate report to the police. Dr. Medardo S. Estanda conducted a medical examination and found the presence of spermatozoa in the victim’s vagina, consistent with recent sexual intercourse. The accused denied the charges, claiming an alibi that he was at a cockpit 11 kilometers away from the crime s Case Digest (G.R. No. 205604) Expanded Legal Reasoning Model
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)