Case Summary (G.R. No. 101858)
Applicable Law
The case is governed by Article 335 of the Revised Penal Code, as amended by Republic Act No. 7659, and further elucidated by Republic Act No. 8353, which pertains to the crime of rape and its penalties.
Summary of the Prosecution’s Case
On April 17, 2000, at approximately 10:00 AM, AAA was gathering firewood in a coconut plantation near her home when Leonardo Castrodes approached her. He forcibly seized the bolo she was using and carried her to a secluded spot under a coconut tree. Despite her attempts to resist due to fear of being harmed, Castrodes physically overpowered her, removing both their clothing and attempting to penetrate her. AAA struggled, cried out in pain, and felt threatened when he warned her against disclosing the incident. She remained silent until April 26, 2000, when her uncle discovered her distress and encouraged her to report the crime.
Introduction of the Defense
In contrast, Castrodes, supported by his cousin Jovenciano Castrodes, claimed an alibi, stating he was at a farm working at the time of the incident. They depicted a detailed timeline asserting that he could not have been present at the site of the alleged crime.
Trial Court Findings
The Regional Trial Court (RTC) found Castrodes guilty beyond a reasonable doubt of rape, sentencing him to reclusion perpetua and ordering him to pay damages to AAA. The decision highlighted the gravity of the crime and the trauma inflicted on the minor victim.
Court of Appeals Decision
The Court of Appeals (CA) upheld the RTC's decision with modifications. It dismissed Castrodes' assertions questioning AAA's credibility, emphasizing that young victims often do not fabricate such grave allegations and typically face societal ramifications when disclosing such offenses. The CA noted that the delay in reporting the incident was not unusual for a victim of rape, particularly a young girl.
Ruling on Alibi and Evidence
The CA found inadequacies in Castrodes' alibi, adjudging it insufficient to establish his physical unavailability at the crime scene given its proximity. Furthermore, the court reiterated that the abse
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Case Background
- The case involves an appeal filed by Leonardo Castrodes, the accused-appellant, against the Decision of the Court of Appeals dated May 31, 2012.
- The appellate court affirmed the conviction of Castrodes by the Regional Trial Court (RTC) for the crime of Rape, committed on April 17, 2000.
- The case is governed by Article 335 of the Revised Penal Code, as amended by Republic Act No. 7659.
Facts According to the Prosecution
- On April 17, 2000, at approximately 10 AM, 15-year-old AAA was gathering firewood in a coconut plantation near her home in San Miguel, Bohol.
- Accused-appellant Leonardo Castrodes approached AAA, forcibly took her bolo (a type of machete), and embraced her.
- He carried AAA to a secluded spot under a coconut tree, where he initiated unwanted sexual advances, including kissing and caressing her.
- Castrodes forced AAA to lie down, removed her shorts and underwear, and exposed himself, ultimately penetrating her despite her efforts to resist.
- After the assault, Castrodes threatened AAA against disclosing the incident, which led her to remain silent until she confided in her uncle, CCC, on April 26, 2000.
Version of the Defense
- In contrast, Castrodes claimed he was with his cousin, Jovenciano Castrodes, working on a farm approximately twenty minutes