Case Summary (G.R. No. 8750)
Background
The Information accused Leonardo Battad of raping AAA on April 9, 2004, with the allegation that he did so by means of force and intimidation. The accused were arraigned on April 13, 2005, pleading not guilty. The trial proceeded after pre-trial concluded on May 11, 2005. The prosecution primarily relied on the testimony of the victim, AAA, a 17-year-old who recounted being accosted by the accused while tending to her livestock.
Antecedent Facts
AAA testified that she encountered Battad and Bacnis while they were drinking at her uncle's house. Following this encounter, she was forcibly taken to a secluded area where both accused raped her. AAA stated they threatened her life should she disclose the incident. Subsequently, AAA's pregnancy was discovered, leading her to inform her mother about the assault after suffering a miscarriage.
Testimonies of the Prosecution
The prosecution's key witness, AAA, described how the two men took turns in raping her while physically restraining her. Dr. Judylyn Rondaris-Eugenio, who examined AAA, corroborated her claims by confirming that AAA was 5 to 6 months pregnant at the time of the examination, consistent with the timeline of the alleged rape.
Defense of the Accused
In their defense, both accused claimed alibis. Bacnis stated he was attending a public event that precluded him from committing the crime, while Battad denied knowing either AAA or Bacnis prior to the case. They characterized AAA's claims as implausible due to the alleged lack of resistance and suggested that her pregnancy and timing of the medical examination did not establish direct culpability.
Ruling of the Trial Court
The RTC found AAA's testimony credible despite minor inconsistencies about the sequence of events. The court highlighted her status as a minor and her perceived mental capacity. Both accused were convicted of rape, with Battad receiving the sentence of reclusion perpetua and Bacnis receiving a lesser sentence due to a mitigating circumstance.
Court of Appeals Decision
Upon appeal, the Court of Appeals affirmed the RTC's decision, maintaining the conviction of Battad for rape under Article 266-A of the Revised Penal Code. The CA noted the prosecution's adequate proof of force and intimidation, notwithstanding the accused's unsupported claims of alibi.
Supreme Court Ruling
Upon further appeal to the Supreme Court, the Court found no basis to overturn the Conviction. The ruling underscored that the victim's narrative was compelling enough given her circumstances. The Court reiterated that lack of physical resistance does not negate the presence of force or intimidation utilized during the crime. Additionally, the Supreme Court clarified that AAA's pre
...continue readingCase Syllabus (G.R. No. 8750)
Case Overview
- This case involves an appeal from the Decision dated July 19, 2012, of the Court of Appeals (CA) affirming the conviction of accused-appellant Leonardo Battad for the crime of Rape.
- The conviction was rendered by the Regional Trial Court (RTC) of Cabugao, Ilocos Sur, Branch 24, on November 12, 2010.
Background of the Case
- The RTC found both Leonardo Battad and Marcelino Bacnis guilty beyond reasonable doubt of the crime of rape.
- Battad was sentenced to reclusion perpetua, while Bacnis received a lesser sentence due to the presence of a privileged mitigating circumstance.
- The accused were ordered to pay joint civil damages to the victim.
Information Filed
- The Information charged Battad and Bacnis with the crime of rape, stating that on or about April 9, 2004, in Ilocos Sur, they unlawfully had carnal knowledge of the victim, AAA, through force and intimidation.
Arraignment and Trial Proceedings
- Battad was arraigned on April 13, 2005, and entered a plea of NOT GUILTY.
- Pre-trial concluded on May 11, 2005, followed by the trial on the merits.
Prosecution's Evidence
- The prosecution presented AAA, a 17-year-old complainant, who testified about the events of April 9, 2004.
- AAA described how she was accosted by the accused while tending to her livestock, forced to a secluded area, and raped by both men.
- Dr. Judylyn Rondaris-Eugenio, a medical officer, examined AAA and