Case Summary (G.R. No. 183100)
Charges and Initial Proceedings
On March 26, 1999, the Provincial Prosecutor of Quezon filed an information in the Regional Trial Court (RTC) against Abrencillo, charging him with qualified rape. The information stated that on March 1, 1999, while armed with a bolo and taking advantage of AAA's minority, Abrencillo allegedly had carnal knowledge of her against her will. The accused pleaded not guilty on September 6, 2000.
Background and Testimonies
AAA's testimony revealed that she and her twin sister, CCC, had regarded Abrencillo as their father, addressing him as "itay." The incident occurred when BBB left to sell fish, leaving AAA alone. Upon returning, Abrencillo allegedly threatened AAA with a bolo, resulting in her inability to resist his sexual advances. After the assault, AAA reported the incident to her grandfather, Lolo Armin, and subsequently underwent a physical examination by Dra. Constancia Mecija, who found an old healed hymenal laceration but no signs of recent physical injuries.
RTC Decision and Sentencing
On March 4, 2002, the RTC found Abrencillo guilty of qualified rape, deeming AAA's testimony credible, corroborated by medico-legal findings. The court sentenced him to death, ordering him to pay AAA P75,000.00 in indemnity and P50,000.00 in moral damages.
Court of Appeals Findings
Upon appeal, the Court of Appeals affirmed the conviction but downgraded the charge to simple rape, stating that Abrencillo was not legally AAA's stepfather due to him and BBB being in a common-law relationship. The CA sentenced him to reclusion perpetua, maintaining the damages awarded by the RTC.
Supreme Court Review and Conclusions
In its review, the Supreme Court emphasized the respect owed to the findings of both the RTC and CA, regarding their observations of AAA’s demeanor during testimony. The court found that despite the absence of recent physical injuries, the credible testimony of AAA supported a finding of carnal knowledge, which does not necessarily require penetration.
The Supreme Court rejected Abrencillo's claim that old healed hymenal lacerations proved there was no recent sexual encounter. It reiterated that evidence proving the absence of physical injuries does not negate the occurrence of rape, as the testimony of the victim can suffice.
The court concurred with the CA’s adjustment of the conviction to simple rape, noting that
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Case Overview
- This case involves an appeal by Rogelio Abrencillo against his conviction for the rape of AAA, the 15-year-old daughter of his common-law wife, BBB.
- The Regional Trial Court (RTC) sentenced him to death on March 4, 2002, based on the qualifications of the crime stemming from his relationship with the victim as her stepfather and her minority.
- The Court of Appeals (CA) later affirmed the conviction but downgraded the crime to simple rape, imposing a penalty of reclusion perpetua instead.
Factual Background
- The accused and BBB began cohabiting when AAA and her twin sister, CCC, were about three years old.
- A father-daughter relationship developed over the years, with AAA and CCC referring to Rogelio as "itay" (father).
- On March 1, 1999, AAA was left alone at home while BBB went out to sell fish.
- The accused returned home, whereupon he initiated sexual contact with AAA, threatening her with a bolo (machete) when she resisted.
- Following the assault, AAA immediately reported the incident to her grandfather, Lolo Armin, who accompanied her to the police station.
Medical Examination Findings
- AAA underwent a physical examination about two hours post-assault conducted by Dra. Constancia Mecija.
- Findings included:
- Fully grown pubic hair and no evident si