Case Digest (G.R. No. 229209)
Facts:
In December 2010 at Sitio Anahaw, Barangay Otod, San Fernando, Romblon, ZZZ, then in his advanced years and the grandfather of AAA (15 years old), allegedly raped her by force, threat, and intimidation, taking advantage of her minority. AAA, who could neither read nor write, executed a sworn statement with the assistance of a DSWD officer. She testified that after weeding grass near their house, ZZZ placed himself on top of her, kissed her lips and genitals, undressed her, turned her sideways, and inserted his penis into her vagina. The next day, she escaped further harm when ZZZ attacked her with a bolo; she parried his strikes, fled, and sought help from Barangay Captain Manuel Lotec. On January 9, 2011, Lotec found AAA “pale and trembling” and brought her to the police station, where social worker Rosa Ravalo translated her Tagalog affidavit into Visayan and attended her medical examination by Dr. Lolinie Celestial B. Montojo, who documented old healed lacerations on the hym
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Case Digest (G.R. No. 229209)
Facts:
- Charge and Arraignment
- Accused ZZZ, grandfather of victim AAA, was charged with rape under Article 266-A of the Revised Penal Code for carnal knowledge of his 15-year-old granddaughter in December 2010 at Sitio Anahaw, Brgy. Otod, San Fernando, Romblon.
- ZZZ pleaded not guilty and trial ensued.
- Prosecution Evidence
- AAA’s testimony described repeated rape incidents by her grandfather in December 2010, her escape to the forest after the act, and a subsequent attack with a bolo when she tried to return home.
- Barangay Captain Manuel Lotec testified that on January 9, 2011 he received a report that AAA “was being chased and raped” and observed her as “pale and trembling.”
- Social worker Rosa Ravalo assisted AAA in executing her affidavit, translated her statement from Tagalog to Visayan, and accompanied her to the medical examination.
- Dr. Lolinie Montojo issued a medico-legal certificate noting old, healed lacerations of AAA’s hymen.
- Defense Evidence
- ZZZ testified in denial and claimed that his advanced age rendered him impotent and incapable of erection.
- Lower Court Decisions
- The RTC of Romblon found AAA’s testimony credible, sufficiently corroborated by the medico-legal certificate and supporting witnesses, convicted ZZZ of rape, imposed reclusion perpetua, and awarded ₱75,000 civil indemnity and ₱50,000 moral damages.
- The Court of Appeals affirmed the conviction, reduced civil indemnity to ₱50,000, awarded ₱30,000 exemplary damages, and retained other penalties.
- Supreme Court Proceedings
- ZZZ filed a Petition for Review on Certiorari questioning the sufficiency of evidence and witness credibility.
- The Supreme Court ordered supplemental briefs and took up the sole issue of guilt beyond reasonable doubt.
Issues:
- Main Issue
- Whether the prosecution proved beyond reasonable doubt that ZZZ committed rape under Article 266-A, RPC.
- Subsidiary Issues
- Whether AAA’s testimony was credible and sufficiently corroborated.
- Whether ZZZ’s impotence defense negated the element of carnal knowledge.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)