Case Summary (G.R. No. 262600)
Procedural History
AAA was charged with 24 counts of rape through Informations filed on January 12, 2016. While the Regional Trial Court found AAA guilty of seven counts of rape, the Court of Appeals modified this ruling, convicting him of six counts of rape and acquitting him of one count. AAA subsequently appealed this decision to the Supreme Court.
Summary of Allegations
The Information filed in the criminal cases indicates that, between December 1 and December 24, 2015, AAA, as the stepfather of BBB, committed sexual acts against her by means of force, violence, and intimidation. Specifically, on multiple occasions, it is alleged that AAA threatened to kill BBB's family if she resisted. BBB recounted detailed occurrences where AAA would enter her room and sexually assault her while her mother was away.
Testimony of the Victim
During the trial, BBB testified regarding the sexual assaults, describing how they occurred during early morning hours, with AAA removing both their clothing before engaging in sexual acts. She detailed how her inability to voice her distress stemmed from AAA's threats of physical harm toward her family.
Medical Evidence
Dr. Editha Martinez conducted a medico-legal examination on BBB, confirming the presence of deep healed lacerations consistent with sexual assault. The report supported BBB's testimony by reflecting signs of blunt penetrating trauma that confirmed penetration, reinforcing the prosecution’s case.
Defense Arguments
AAA denied the allegations and claimed that he was sleeping in a different room, asserting it would have been impossible for him to commit the alleged offenses. He also cited his physical inability to overpower BBB due to having lost his left hand in an accident. AAA further attempted to suggest that the charges were motivated by a familial misunderstanding.
Trial Court Findings
The Regional Trial Court concluded that while there was substantial evidence for some counts of rape, the latter dates of December were not sufficiently supported due to BBB's generalized testimony regarding those incidents. The trial court emphasized the significance of moral ascendancy, noting that physical force may not be necessary when the accused has significant influence over the victim.
Court of Appeals Decision
In its ruling, the Court of Appeals upheld the conviction for six counts of rape, clarifying that while there was proof of serious emotional and psychological intimidation, the necessary legal standards for qualified rape were not met because there was insufficient evidence demonstrating AAA's legal marriage to BBB's mother, which is typically required to establish stepfather-stepparent qualifications.
Supreme Court's Conclusions
The Supreme Court upheld the Court of Appeals' ruling, affirming the convict
...continue readingCase Syllabus (G.R. No. 262600)
Case Background and Charges
- The accused-appellant AAA was charged with 24 counts of rape under Article 266-A of the Revised Penal Code, as amended.
- The Informations, all filed on January 12, 2016, alleged that AAA, as the step-father of the 15-year-old minor BBB, committed acts of rape against her from December 1 to December 24, 2015.
- Each Information described similar acts involving force, violence, and intimidation with lewd designs.
- AAA pleaded not guilty and the trial followed.
Facts Presented at Trial
- BBB testified that AAA would sexually abuse her in her room early in the mornings when her mother was absent.
- AAA threatened BBB with harm to her family to keep her from resisting or shouting.
- The assaults were repeated over the period, involving the accused removing her clothes and having carnal knowledge of her.
- BBB’s room door lock was broken, facilitating the assaults.
- BBB eventually confided in her sister EEE, who helped her file a complaint.
- Medico-legal examination confirmed the presence of deep healed laceration and evidence of blunt penetrating trauma to the hymen.
- AAA denied the accusations, claiming physical impossibility of being in BBB’s room and noting his physical disability (loss of left hand).
Trial Court Findings and Judgment
- The Regional Trial Court (January 30, 2020) convicted AAA of seven counts of rape but acquitted him of others for insufficiency of evidence.
- It found that rape from December 8 to 24, 2015, was not proven with the required quantum of evidence.
- The court noted that AAA and BBB’s mother were common-law partners, not legally married; hence, the stepfather-stepdaughter relationship as a qualifying circumstance was not applicable.
- AAA was sentenced to reclusion perpetua per count, including moral, civil indemnity, and exemplary damages.
Court of Appeals Decision
- The Court of Appeals affirmed the conviction but modified it, finding AAA guilty of six counts of rape instead of seven.
- The court acquitted AAA of several counts for insufficiency of evidence.
- It increased the awards for moral, civil, and exemplary damages to Php100,000 per count.
Issues on Appeal to the Supreme Court
- The main issue is whether AAA is guilty beyond reasonable doubt of six counts of rape.
- The case raised questions about the qualifying circumstance of the accused being a stepfather, given the common-law relationship with the victim’s mother.
Legal Discussion on the Qualifying Circumstance
- Article 266-A specifies rape is qualified if committed by a parent, ascendant, step-parent, guardian