Case Summary (G.R. No. 207990)
Background Details
The narrative began when AAA's biological mother, BBB, abandoned the family, leading her father, CCC, to place AAA and her siblings in the care of the accused-appellant and his common-law wife. The victim alleged that the accused raped her on four distinct occasions in 2004, with incidents dated June 14, July 7, August 18, and September 13. Following the last incident, where the victim reported the assaults, four cases were filed against the accused in the Regional Trial Court (RTC) of San Jose, Camarines Sur.
Allegations of Rape
In the complaints, it was stated that the accused-appellant forcibly had carnal knowledge of the victim, emphasizing that at the time of the offenses, she was thirteen years old and he was in a position of authority as her stepfather. The descriptions of each incident depicted a pattern of violence and coercion, where the accused-appellant used threats or physical intimidation to complete the assaults.
Prosecution's Evidence
The prosecution presented the testimonies of AAA, her father CCC, Dr. Jane Perpetua Fajardo, a Medicolegal Officer, and Police Officer 1 Fara M. Bolong. AAA's testimony was detailed, recounting the nature of each assault, and was consistent throughout, despite being subjected to a rigorous cross-examination. Dr. Fajardo’s examination revealed that while AAA's hymen showed no lacerations, it was pliable, indicating prior penetrative acts.
Defense Testimony
The defense rested on the testimony of the accused-appellant, who denied the allegations and claimed to have been elsewhere during each incident. His assertions were unsupported by corroborating evidence, and his common-law wife did not testify despite being subpoenaed. The accused tried to dismiss the charges as fabricated, suggesting AAA had motives to tarnish his reputation.
Ruling of the RTC
On August 25, 2009, the RTC convicted the accused-appellant of four counts of simple rape, imposing the penalty of reclusion perpetua. The court ruled that AAA’s clear and compelling testimony sufficed as evidence of the crime, and the accusations of lack of physical evidence (like hymenal lacerations) did not diminish her claims. The RTC also clarified the absence of evidence regarding the alleged relationship of stepfather and stepdaughter, which changed the context from qualified to simple rape.
Court of Appeals Review
Upon appeal, the accused-appellant argued mainly against the credibility of AAA’s testimony and the prosecution’s failure to prove the alleged facts regarding her injury and the timeline of reporting. The Office of the
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Case Overview
- The case revolves around G.R. No. 207990, decided on June 9, 2014, by the First Division of the Supreme Court of the Philippines.
- The People of the Philippines (plaintiff-appellee) filed charges against Elias Buenvinoto y Paglinawan (accused-appellant) for four counts of simple rape of a minor, AAA, who was 13 years old at the time of the incidents.
- The Regional Trial Court (RTC) of San Jose, Camarines Sur, Branch 30, found the accused guilty and sentenced him to reclusion perpetua for each count, alongside financial damages awarded to the victim. The Court of Appeals (CA) affirmed the RTC’s decision.
Background Facts
- AAA's biological mother, BBB, abandoned the family, leaving AAA and her four siblings under the care of their father, CCC.
- At 7 months old, AAA was verbally given to the accused-appellant and his common-law wife for care, but this arrangement was never formalized.
- AAA alleged that she was raped on four occasions in 2004: June 14, July 7, August 18, and September 13.
- Following the last incident, AAA reported the rapes to authorities, leading to the filing of four separate informations against the accused-appellant.
Details of Allegations
- The charges described specific dates and circumstances of the alleged rapes, focusing on the use of force and intimidation by the accused-appellant against AAA.
- Each incident involved AAA being threatened with a knife, physically restrained, and raped despite her attempts to resist.
Evidence Presented
- The prosecution's case included testimonies from AAA, her father CCC, Dr. Jane Perpetua Fajardo (the medicolegal officer), and Police Offi