Case Digest (G.R. No. 214497) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines v. Eduardo Quimvel y Braga, petitioner Eduardo Quimvel y Braga was charged with Acts of Lasciviousness in relation to Section 5(b), Article III of Republic Act No. 7610 before the Regional Trial Court (RTC) of Ligao City, Albay. The Amended Information alleged that on or about 8 p.m. of July 18, 2007 at Palapas, Ligao City, Quimvel, with “lewd and unchaste design” and “through force and intimidation,” inserted his hand into the undergarment of AAA, a seven-year-old child, and caressed her vagina against her will. At trial, the child victim testified she woke up to find Quimvel’s leg on her body and his hand inside her shorts. The RTC, finding her testimony credible, convicted Quimvel on January 23, 2013 and sentenced him to fourteen years, eight months, and one day to fifteen years, six months, and nineteen days of Reclusion Temporal in its medium period, with moral damages of ₱30,000 and a fine of ₱30,000. The Court of Appeals (CA) affirmed on May 2 Case Digest (G.R. No. 214497) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and relationships
- AAA, a 7-year-old minor, lived with her father (YYY) and two siblings in Palapas, Ligao City; her mother worked in Batangas.
- Eduardo Quimvel y Braga was caretaker of AAA’s grandfather’s ducks and resided a few meters from AAA’s home.
- Incident and investigation
- On July 18, 2007 at around 8:00 PM, YYY left the house to buy kerosene. Quimvel arrived with a vegetable viand and agreed to stay with the children at AAA’s request.
- AAA fell asleep and later awoke to feel Quimvel’s right leg on her body and his right hand inside her shorts, caressing her vagina; she removed his hand. Quimvel left upon YYY’s return.
- When AAA’s mother (XXX) returned on July 29, 2007, siblings revealed Quimvel’s conduct. Parents reported the incident to barangay and police authorities and AAA underwent a medical examination confirming sexual abuse.
- Quimvel denied the allegations, claiming he never went to AAA’s house that evening and alleged he was elsewhere with the ducks.
- Proceedings below
- RTC Ligao City, Branch 11: Convicted Quimvel of Acts of Lasciviousness in relation to Sec. 5(b), RA 7610; sentenced to 14 years, 8 months, 1 day to 15 years, 6 months, 19 days reclusion temporal; ordered P30,000 moral damages and P30,000 fine (credited preventive detention).
- CA (May 29, 2014): Affirmed with modification—ordered P15,000 moral damages, P15,000 exemplary damages, P20,000 civil indemnity; 6% interest from finality.
Issues:
- Did the prosecution prove Quimvel’s guilt beyond reasonable doubt?
- If guilty, should Quimvel instead be convicted under Art. 336 RPC (Acts of Lasciviousness) rather than in relation to Sec. 5(b), RA 7610?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)