Case Summary (G.R. No. 186232)
Nature of Charges
The accused was charged with five counts of rape, with the incidents occurring between January 6, 1997, and February 14, 2001, against AAA, his daughter. The rapes were perpetrated under circumstances involving the use of force and intimidation when AAA was aged thirteen to seventeen.
Trial and Evidence Presented
During the trial, the prosecution presented testimonies from five witnesses, including AAA, her mother (BBB), a medical doctor, and a police officer. The evidence indicated a pattern of abuse and intimidation that prevented AAA from reporting the incidents immediately. Physical examinations confirmed old healed hymenal lacerations, suggesting prior sexual intercourse.
Defense Arguments
The defense, led by Alejandro, claimed alibi, stating he was at work or away from home during the alleged incidents. He presented a narrative of being with relatives during critical times, arguing the absence of any marks or visible injuries on AAA to support her claims. He also challenged the timeline provided by AAA, noting inconsistencies in her testimony regarding specific dates of the incidents.
RTC Ruling
On April 15, 2003, the Regional Trial Court (RTC) found Alejandro guilty beyond reasonable doubt of all five counts of rape and sentenced him to death for each count while ordering substantial damages to AAA, including moral and civil indemnities.
Appeal to Court of Appeals
Alejandro appealed the RTC’s decision, claiming errors regarding the sufficiency of evidence for carnal knowledge and credibility of AAA’s testimony. He contested findings of the RTC regarding the events and raised doubts concerning the timeline of incidents.
Court of Appeals Decision
On October 15, 2008, the Court of Appeals affirmed the RTC's findings but modified the sentence from death to reclusion perpetua without eligibility for parole, in accordance with Republic Act No. 9346, the Anti-Death Penalty Law. It also adjusted the damages awarded to AAA, maintaining the moral and civil indemnities but increasing the exemplary damages.
Supreme Court Review and Final Findings
The case was subject to automatic review by the Supreme Court. Though the Court recognized minor inconsistencies in AAA’s testimony, it underscored that they did not detract from the essence of the crime, which was established beyond reasonable doubt. The Court concluded that the prosecution proved its case with credible testimonies corroborated by medical
...continue readingCase Syllabus (G.R. No. 186232)
Case Overview
- The case involves an appeal by Elpidio Parohinog Alejandro against the decision of the Court of Appeals affirming his conviction for five counts of rape against his daughter, AAA.
- The original ruling was issued by the Regional Trial Court (RTC) of Isulan, Sultan Kudarat on April 15, 2003, where Alejandro was found guilty and sentenced to death.
- The appeal was elevated to the Supreme Court due to the imposition of the death penalty.
Charges and Allegations
- Alejandro faced five counts of rape, each characterized by the involvement of force and intimidation against his daughter, AAA.
- The specific incidents of rape occurred on various dates:
- January 6, 1997: AAA, aged 13, was assaulted while she was sleeping.
- July 1998: AAA, aged 14, was again assaulted in their home.
- September 1999: AAA, aged 15, was assaulted while alone with Alejandro.
- April 1, 2000: AAA, aged 16, was assaulted after being ordered to buy a match.
- February 14, 2001: AAA, aged 17, was assaulted after being fetched from school.
Trial Proceedings
- Alejandro was arraigned on November 12, 2001, and pleaded not guilty to all charges.
- The prosecution presented five witnesses, including the victim, her mother, and medical professionals who conducted examinations.
- Testimonies described the details of each rape incident, including the violence and coercion involved.