Case Summary (G.R. No. 203114)
Facts of the Case
The case revolves around accusations against the petitioner, Virgilio Labandria Awas, for acts of lasciviousness in connection with an incident involving a 10-year-old girl (AAA). The incident occurred on January 24, 2010, in Valenzuela City, where it was alleged that the petitioner unlawfully inserted his finger into the victim's vagina. The petitioner pleaded not guilty and the case proceeded through pre-trial and trial phases.
Evidence Presented
During the prosecution's case, AAA testified that the petitioner, who was known to her as her sister's boyfriend, called her into a room and touched her inappropriately. While the defense argued the victim had not protested during the incident or sought help, AAA's brother learned of the incident when he found her crying and reported it to their mother, which led to the petitioner's arrest. The medico-legal findings indicated normal genital examination results without evidence of sexual abuse, but the court considered the victim's credibility despite this.
Ruling of the Regional Trial Court
The Regional Trial Court found Awas guilty of acts of lasciviousness under Article 336 of the Revised Penal Code. The court imposed a sentence of 12 years and one day of reclusion temporal as minimum, to 15 years and six months as maximum, along with moral damages and a fine. The prosecution successfully established that Awas had indeed touched AAA's vagina, which constituted acts of lasciviousness.
Appeal to the Court of Appeals
Following the RTC's decision, Awas appealed, arguing that the prosecution failed to meet the burden of proof required to establish his guilt. He contended that the victim's behavior during the incident was inconsistent with typical reactions to such a crime, which should have prompted dismissal of the charges. The Court of Appeals denied the appeal, affirming the RTC's findings and modifying damages awarded to AAA.
Supreme Court Rationale
The Supreme Court found the appeal lacked merit, upholding the lower court’s decisions regarding the credibility of AAA's testimony, and reiterated that the testimony of the offended party is sufficient to establish guilt in cases of lasciviousness if credible. The court stressed that the victim's lack of protest does not absolve the accused of responsibility, given the victim’s age and the nature of the offense.
Legal Standards and Principles
The court underscored that under Article 336 of the Revised Penal Code, acts of lasciviousness involve specific elements: the unlawful act performed with a minor, and with or without force or intimidation. Additionally, Republic Act No. 7610, which enhances protections for minors against sexual abuse, reinforces the legal stance on the age factor. The Supreme Court highlighted the importance of aligning penalties with child protection statutes.
Modification of Se
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Case Overview
- This case involves the petitioner, Virgilio Labandria Awas, who was convicted of acts of lasciviousness under Article 336 of the Revised Penal Code and in relation to Section 5(b), Article III of Republic Act No. 7610.
- The original decision by the Regional Trial Court (RTC) was rendered on February 4, 2011, and was later modified by the Court of Appeals (CA) on May 8, 2012, which upheld the conviction.
Incident Description
- The incident occurred on January 24, 2010, in Valenzuela City, involving the petitioner and the victim, identified as AAA, a 10-year-old minor.
- The information charged the petitioner with the unlawful insertion of his finger into the vagina of the victim against her will and without her consent.
- It was alleged that the petitioner had employed force and intimidation during the act.
Trial Proceedings
- The petitioner pleaded not guilty on February 12, 2010, leading to pre-trial and trial proceedings.
- During the pre-trial on April 16, 2010, the parties stipulated that the victim was a minor at the time of the offense.
Prosecution's Evidence
- The victim, AAA, testified that the petitioner, who was her sister's boyfriend, had called her into a room and touched her inappropriately.
- She described being alone with the petitioner at the time of the incident, who warned her not to tell her parents afterward.
- A medico-legal examination revealed normal genital findings but did not negate the possibility of sexual abuse.