Case Summary (G.R. No. 135457)
Charges and Relevant Facts
BBB was charged in three separate Informations:
- Criminal Case No. 12493: Violation of Section 5(i) of Republic Act No. 9262 for causing violence against his common-law wife DDD by sexually abusing their daughters, AAA and CCC.
- Criminal Case No. 12605: Rape of AAA, then 13 years old, on December 10, 1999.
- Criminal Case No. 12606: Rape of CCC, also 13 years old, on March 30, 2004.
Both victims testified that they were subjected to sexual violence by BBB, who threatened them with harm if they reported the incidents.
Judicial Proceedings
The Regional Trial Court found BBB guilty beyond reasonable doubt, ruling that the testimonies of AAA and CCC were credible and corroborated by medical evidence, including physical examinations indicating the presence of prior sexual trauma. BBB's defenses of alibi and denial were deemed insufficient compared to the compelling and consistent accounts of the victims.
Decision of the Regional Trial Court
The Regional Trial Court’s dispositive portion included:
- A sentence of reclusion perpetua for each rape count (Criminal Case Nos. 12605 and 12606).
- An indeterminate sentence for the violation of R.A. 9262 ranging from two years and one day to four years and two months.
- Monetary damages awarded to the victims, including civil indemnity, moral damages, and exemplary damages.
Appeal to the Court of Appeals
BBB appealed the decision, arguing that the testimonies of the victims were motivated by a desire to eliminate him from DDD's life, and sought to emphasize an alibi based on a business meeting he claimed to have attended instead of being present in two incidents of rape.
Ruling of the Court of Appeals
The Court of Appeals upheld the lower court's ruling, validating the credibility of the victims' testimonies and finding that BBB's alibi did not hold sufficient weight against the clear evidence of abuse. The appellate court modified the award of damages according to recent jurisprudence and confirmed the sentences imposed in the lower court regarding both the rape and the violation of the Anti-Violence Against Women and Their Children Act.
Affirmation of Convictions
The Supreme Court further evaluated the appeal, emphasizing that credible testimonies of rape victims, especially when corroborated by medical findings, can establish the elements of the crime beyond reasonable doubt. The Court denied BBB's appeal, reinforcing the lower courts' findings regarding the sufficiency of evidence establishing guilt and the proper applica
...continue readingCase Syllabus (G.R. No. 135457)
Case Overview
- This case involves an appeal by BBB, the accused-appellant, contesting his conviction for multiple crimes including two counts of qualified rape and a violation of Republic Act No. 9262 (Anti-Violence Against Women and Their Children Act).
- The Regional Trial Court (RTC) initially found BBB guilty beyond reasonable doubt, leading to his appeal to the Court of Appeals (CA).
- The CA affirmed the RTC's decision with modifications regarding penalties and damages.
Facts of the Case
- BBB was charged with three separate Informations for committing violence against his common-law wife DDD and raping her two minor stepdaughters, AAA and CCC.
- The incidents occurred on December 10, 1999, and March 30, 2004, involving threats and coercion, with both victims being 13 years old at the time of the offenses.
- AAA testified that BBB entered her room, threatened her with a gun, and raped her. Initially, she confided in her mother DDD, who did not believe her.
- CCC's testimony revealed a similar pattern of coercion and threats by BBB shortly after AAA's incident.
- The sisters eventually reported the incidents to their mother and the National Bureau of Investigation (NBI).
Prosecution's Evidence
- Medical examinations conducted by a municipal health officer revealed old lacerations in the hymens of both AAA and CCC, indicating prior