Case Digest (G.R. No. 249414) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines vs. Benny Dalaguet (G.R. No. 249414, July 27, 2022), the accused-appellant, Benny Dalaguet, was charged in two separate Informations dated March 29, 2010, before the Regional Trial Court (RTC), Branch 45 of Bais City, for violations of Section 5(b) of Republic Act No. 7610 (the Special Protection of Children Against Abuse, Exploitation, and Discrimination Act). In Criminal Case No. F-10-49-MJ, Dalaguet was accused of willfully and unlawfully having sexual intercourse with AAA, then a 15-year-old minor, by means of force, coercion, and intimidation in December 2009 at a field hut. In Criminal Case No. F-10-50-MJ, he was similarly accused of the same acts in March 2010 at AAA’s home. AAA, her grandfather EEE, and a social worker testified for the prosecution. AAA described two incidents in which Dalaguet carried her to a hat hut and later held her down at her residence, undressed them both, and made “push and pull” movements though no penile penetratio Case Digest (G.R. No. 249414) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Charges and Proceedings
- Two informations (March 29, 2010) charged Benny Dalaguet with violations of Section 5(b), R.A. No. 7610, for two separate incidents of alleged sexual acts against AAA, a 15-year-old neighbor, in December 2009 and March 2010.
- Pre-trial stipulations confirmed (a) identities and victim’s age; (b) neighbor relationship; and (c) that Dalaguet entered AAA’s house on March 9, 2010.
- Evidence Presented
- AAA testified to two incidents: in a field leading to a nipa hut (Dec 2009) and at home (Mar 9, 2010), describing being carried or led, undressed, held tightly, shouted for help, threatened if she spoke, and “sexual intercourse” without penile penetration.
- Corroborative evidence: EEE (grandfather) witnessed the second incident; Dr. Andaya’s certificate noted healed genital lacerations; social worker Rubio conducted a family study.
- Defense: Dalaguet denied the offenses, claimed he merely retrieved his cellphone, and alleged unlawful arrest and lack of knowledge of the December incident.
- Lower Court Decisions
- RTC (July 13, 2016) convicted Dalaguet of two counts of rape (RA 7610 construed under RPC Articles 335–336), imposing reclusion perpetua and damages totaling P200,000.
- CA (June 25, 2019) modified the conviction to two counts of lascivious conduct (Sec 5(b), RA 7610), sentencing prision mayor (medium) to reclusion temporal and awarding P50,000 each for civil indemnity, moral and exemplary damages per count.
Issues:
- Whether the Court of Appeals erred in convicting Dalaguet of lascivious conduct under Section 5(b), RA 7610 despite the prosecution’s failure to prove rape through sexual intercourse beyond reasonable doubt.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)