Case Summary (G.R. No. 244835)
Applicable Law
The case arises under the Revised Penal Code of the Philippines and Republic Act No. 8353 (Anti-Rape Law of 1997) alongside Republic Act No. 7610 (Special Protection of Children Against Abuse, Exploitation, and Discrimination Act).
Factual Background
ABC faced charges for the alleged rape of his nine-year-old daughter, AAA. Both cases outlined incidents where ABC used force and intimidation to abuse his daughter sexually. The first charge involved an act allegedly committed between January 13 and January 21, 2011, while the second occurred between April and May 2011. Upon examination during the trial, evidence revealed disturbing details of the alleged rapes, including threats made by ABC to prevent AAA from reporting the incidents.
Trial Proceedings
Upon arraignment in October 2014, ABC pleaded not guilty. The prosecution presented several witnesses, including AAA, who provided a consistent account of the alleged abuse. The trials were characterized by AAA's and other witnesses' testimonies, describing the events in detail while ABC's defense was solely a denial of the accusations, claiming they were fabricated.
RTC Ruling
The Regional Trial Court found ABC guilty of acts of lasciviousness in relation to the first charge (Criminal Case No. R-QZN-14-07928-CR) but acquitted him of rape due to insufficient evidence regarding penetration. However, he was found guilty of rape in the second charge (Criminal Case No. R-QZN-14-07929-CR) and was sentenced to reclusion perpetua. The RTC emphasized that the prosecution had sufficiently proven the elements of rape.
Court of Appeals Ruling
The Court of Appeals upheld the RTC’s conviction, affirming that the evidence established all elements of qualified rape. The CA modified the findings related to the first charge, classifying the offense as acts of lasciviousness under Article 336 of the RPC and Republic Act No. 7610. The CA adjusted ABC's sentence on that count but upheld his conviction for rape, ordering substantial damages to AAA.
ABC's Appeal
ABC contended that the prosecution failed to prove the charges against him and argued the testimonies were inconsistent. He insisted that the credibility of the witnesses was not adequately established, which he claimed warranted a reconsideration of his conviction.
Supreme Court's Ruling
The appeal was dismissed, as the Supreme Court affirmed the CA’s findings and penalty. It reiterated the credibility of child witnesses, affirming that youthful victims are given significant weight when their testimonies are consistent and corroborative. The Cour
...continue readingCase Syllabus (G.R. No. 244835)
Overview of the Case
- This case involves an appeal by ABC, the accused-appellant, from the Decision of the Court of Appeals (CA) dated September 27, 2018.
- The CA affirmed the Judgment of the Regional Trial Court (RTC) of Quezon City, Branch 106, which convicted ABC of Acts of Lasciviousness and Rape against his minor daughter, AAA.
- The crimes were charged under Article 336 and Article 266-A of the Revised Penal Code (RPC), as amended by Republic Act (R.A.) No. 8353.
Facts of the Case
- ABC was charged with two counts of Rape in two separate Informations:
- Criminal Case No. R-QZN-14-07928-CR: Allegations of Rape occurring between April and May 2011 against his daughter, AAA, who was 9 years old at the time.
- Criminal Case No. R-QZN-14-07929-CR: Allegations of Rape occurring between January 13 and January 21, 2011, again against AAA.
- During the arraignment on October 9, 2014, ABC pleaded "not guilty" to both charges.
- The prosecution presented witnesses, including AAA, her brothers, and a medico-legal officer, while the defense relied solely on ABC's testimony.
- Evidence indicated that the crimes were committed through force and intimidation, exploiting the father-daughter relationship.
Prosecution's Evidence
- Testimonies revealed the traumatic encounters:
- On January 13 and 21, 2011, AAA was awakened by ABC, who threatened her with a gun and undressed her before sexually assaulting her.
- Following the assaults, AAA suffered physical pain and injuries, which were corroborated by medical examinations conducted by Dr. Charyl Esc