Case Summary (G.R. No. 124043)
Case Background
On January 18, 2000, the trial court found Doroteo AbaAo guilty of raping his daughter, Judelyn, on August 15, 1996, at Barangay Liminangcong, Taytay, Palawan. The court imposed the death penalty based on Republic Act No. 7659, along with civil indemnity and moral damages amounting to P50,000.00 each.
Proceedings
The information filed against AbaAo indicated that he committed the crime through force and intimidation. AbaAo entered a plea of not guilty upon arraignment with the assistance of legal counsel. The prosecution presented several witnesses, including Judelyn and Dr. Nestor A. Reyes, while the defense presented only AbaAo himself without any documentary evidence.
Testimonies
Judelyn testified that she was awakened by her father undressing her and subsequently forcing himself upon her. She cried out for help from a neighbor, Annabelle Fuentes, who heard the cries but was deterred from entering the house by AbaAo's claim that Judelyn was merely having a nightmare. The prosecution's narrative emphasized Judelyn's immediate physical discomfort the following day, indicating the gravity of the incident.
Appellant's Defense
AbaAo denied the allegations, claiming that he and his children were watching television that night and that Judelyn merely experienced a nightmare. His defense rested on the premise that the complainant's testimony lacked corroboration and that he could not be identified as the assailant since Judelyn claimed to not recognize the person who undressed her.
Trial Court's Decision
The trial court found Judelyn's testimony credible, noting her forthrightness and emotional delivery during the trial. The court's conviction relied on the weight of Judelyn’s credible narrative, corroborative medical evidence, and the absence of any ill motive behind her accusations. The trial court underscored that, in cases of rape involving young victims, their testimonies are typically given special evidentiary weight.
Appellant's Appeal
AbaAo appealed his conviction primarily on the basis that the trial court erred in finding him guilty beyond a reasonable doubt of rape. He argued that the court did not adequately apply the principles regarding the nature of evidence in rape cases.
Judicial Analysis
The appellate court assessed the trial court's findings while emphasizing the credibility of witness testimony, especially from minors. Judelyn's testimony was found to be consistent and credible despite minor discrepancies. The appellate court noted that discrepancies in the testimony of a child do not necessarily undermine the case's togetherness.
Legal Principles
Rape, as defined under Article 335 of the Revised Penal Code, constitutes carnal knowledge of a woman by any of several means, including when the victim is under twelve years of age. In this case, Judelyn's age and her relationship to the accused were vital qualifying circumstances under R.A. No. 7659 that elevated the penalty to death.
Conclusion on Penalty
The appellate court affirmed the imposition of the death
...continue readingCase Syllabus (G.R. No. 124043)
Case Background
- The case involves Doroteo AbaAo, accused of raping his six-year-old daughter, Judelyn AbaAo.
- The Regional Trial Court, Branch 52 in Puerto Princesa City, Palawan, found him guilty and imposed the death penalty, along with civil and moral damages.
- The Information charged AbaAo with the crime of rape, alleging that on August 15, 1996, he forcibly had carnal knowledge of his daughter against her will.
Procedural History
- On January 31, 1997, Doroteo AbaAo pleaded not guilty to the charge with the assistance of counsel.
- The trial included testimonies from the complainant (Judelyn), a medical doctor (Dr. Nestor A. Reyes), and a neighbor (Annabelle Fuentes).
- The defense presented Doroteo as its lone witness without any documentary evidence.
Facts of the Case
- Judelyn described being awakened by her father undressing her and subsequently raping her, leading her to cry for help from a neighbor.
- Annabelle Fuentes testified to hearing Judelyn’s cries and witnessing her unusual gait the following day, indicating possible abuse.
- Judelyn was eventually taken for medical examination, which revealed healed hymenal lacerations consistent with rape.
Testimonies
Judelyn AbaAo's Testimony:
- She recounted the details of the assault, including her father undressing her and the physical pain she endured.
- Her testimony was consistent and straightforward, even under cross-examination.
- Judelyn’s emotional state during her testimony indicated the trauma she experienced.
Dr. Nestor A. Reyes’ Testimony:
- He confirmed the findings of old healed hymenal lacerations,