Case Summary (G.R. No. 266706)
Charges and Offenses
ZZZ faced multiple charges including three counts of Rape under Article 266-A of the Revised Penal Code, Rape by Sexual Assault, Acts of Lasciviousness, Child Abuse under Republic Act No. 7610, and Violation of the Anti-Violence Against Women and Children Act under Republic Act No. 9262. The charges stemmed from allegations of sexual and physical abuse of his daughters and wife.
Judgment of the RTC
The Regional Trial Court convicted ZZZ of two counts of Rape, one count of Rape by Sexual Assault, and four counts of Slight Physical Injuries, sentencing him to varying penalties. Specifically, ZZZ received a sentence of reclusion perpetua for qualified rape, as well as monetary damages to be paid to the victims.
Ruling of the Court of Appeals
On appeal, the Court of Appeals affirmed the RTC's decision while modifying the penalties and damages awarded. The CA upheld the convictions for two counts of Rape and one count of Rape by Sexual Assault, emphasizing that moral ascendancy negated the need for proof of physical resistance in these cases.
Evidence Presented
The prosecution provided extensive testimonies from the victims, along with medical certificates and affidavits corroborating the claims of sexual abuse and physical violence. Notably, Dr. Patrick Lawrence Manaois testified about the physical injuries sustained by the victims, including hymenal lacerations and other trauma.
Defense Claims
ZZZ denied the allegations, asserting that the accusations were fabricated due to his strict parenting style. He argued that the lack of visible resistance from the victims during the alleged abuse undermined their credibility. The defense presented testimonies from ZZZ’s relatives suggesting a happy family environment.
Consideration of Credibility
The Court placed significant weight on the credibility of the victims' testimonies, stating that the absence of physical resistance does not negate the occurrence of rape. The Court reiterated an established legal doctrine that understood the dynamics of abuse, highlighting that victims’ responses can vary widely.
Conclusion of the Ruling
The Court ruled that the elements of the crimes of rape and sexual assault were established beyond a reasonable doubt. It recognized that the familial relationship and moral authority constituted a significant power dynamic, which made it unre
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Background and Charges
- The accused-appellant, ZZZ, faced multiple charges including three counts of Rape under Article 266-A, paragraphs 1(a) and 2 of the Revised Penal Code (RPC), three counts of Child Abuse and one count of Acts of Lasciviousness under Republic Act No. 7610, and one count of Violation of Section 5(a) of Republic Act No. 9262.
- The crimes were committed in Dagupan City and involved his minor daughters AAA, BBB, CCC, and DDD, and his wife EEE.
- The charges stem from repeated incidents of sexual abuse and physical violence inflicted by ZZZ on his family members across several years from 2009 to 2017.
Facts of the Case
- Accused ZZZ is the biological father of complainants AAA, BBB, CCC, and DDD, and husband of EEE.
- Beginning April 2009, ZZZ sexually abused his eldest daughter AAA starting when she was 9 years old, including rape and sexual assault incidents.
- Physical abuse included acts such as forcibly pulling hair, punching, choking, and dragging his children and wife.
- Multiple witnesses including the victims and a medical doctor testified regarding the abuse, supported by medical examinations confirming injuries and healed hymenal lacerations.
- The accused admitted to disciplining his children strictly but denied the rape allegations.
Trial Court Ruling
- The Regional Trial Court (RTC) convicted ZZZ of two counts of rape under Article 266-A, paragraph 1(a), one count of rape by sexual assault under Article 266-A, paragraph 2, and four counts of slight physical injuries.
- ZZZ was acquitted of the charges related to Acts of Lasciviousness and Violation of RA 9262 due to reasonable doubt.
- Sentences imposed included reclusion perpetua and varying penalties for other crimes, along with orders to pay civil indemnity, moral, and exemplary damages.
Appeal and Court of Appeals Decision
- On appeal, the Court of Appeals (CA) affirmed the RTC decisions with modifications.
- The CA heightened penalties for rape charges to reclusion perpetua without parole eligibility due to aggravating circumstances of minority and relationship.
- Civil indemnities and damages were increased.
- CA convicted ZZZ for Violation of RA 9262, which was previously acquitted by the RTC.
Supreme Court Issues and Considerations
- Central issue: Whether the CA correctly affirmed the RTC ruling finding ZZZ guilt