Case Summary (G.R. No. 228822)
Procedural History
The appeal arises from the Decision dated June 22, 2016, of the Court of Appeals (CA) in CA-G.R. CR-HC No. 06686, which affirmed with modification the Consolidated Decision of the Regional Trial Court (RTC) of Romblon, dated August 20, 2013, wherein CCC was found guilty beyond reasonable doubt of four counts of rape.
Facts of the Case
CCC was charged with rape in four separate Informations corresponding to incidents that took place on January 7, January 9, January 27, and February 3, 2004. In each instance, it was alleged that CCC had carnal knowledge of his daughter, AAA, using force and intimidation, and without her consent. The prosecution presented key testimony from Dr. Rowena R. Dianco, who conducted a medical examination on AAA, indicating that AAA’s hymen had been ruptured but healed, suggesting prior penetration.
Evidence Presented
During the trial, AAA's mother, BBB, corroborated the events and testified to a noticeable change in AAA's behavior following the incidents. BBB also identified AAA's Certificate of Live Birth, confirming her age. Moreover, a handwritten letter from AAA, discovered after she ran away from home, detailed her traumatic experience and indicated CCC's involvement.
RTC Ruling
The RTC, in its Consolidated Decision, convicted CCC on all four counts of rape. It found BBB's testimony credible, noting that it was never challenged. The court emphasized the totality of evidence supporting the conviction, despite AAA's absence from court due to financial constraints, which resulted in her testimony being expunged.
CA Ruling
The CA upheld the RTC’s ruling but modified the penalty and imposed higher amounts for civil indemnity, moral damages, and exemplary damages. The appellate court found sufficient bases for the convictions, relying heavily on BBB’s testimony and evidence of AAA's behavior and medical findings.
Issue on Appeal
The central issue in the appeal is whether the CA erred in affirming CCC's conviction for rape.
Supreme Court Ruling
The Supreme Court granted the appeal, overturning the lower courts’ convictions. It concluded that the prosecution failed to prove all elements of qualified rape beyond reasonable doubt. The absence of AAA's direct testimony significantly weakened the case, as her statements to BBB were ruled as hearsay and thus i
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Case Background
- This case involves an appeal by CCC against the decision of the Court of Appeals (CA) which affirmed, with modifications, the Consolidated Decision of the Regional Trial Court (RTC) of Romblon, finding CCC guilty of four counts of rape.
- The original decision was rendered on 20 August 2013, with the CA’s ruling dated 22 June 2016.
Charges and Allegations
- CCC was charged with four counts of rape against his daughter, AAA, who was 12 years old at the time of the incidents.
- The specific incidents occurred on:
- Criminal Case No. 2566: 7 January 2004
- Criminal Case No. 2567: 9 January 2004
- Criminal Case No. 2568: 27 January 2004
- Criminal Case No. 2569: 3 February 2004
- All incidents were characterized by force and intimidation, with the aggravating circumstance that CCC was the father of the victim.
Testimonies Presented
- The prosecution presented Dr. Rowena R. Dianco, a Municipal Health Officer, who examined AAA on 19 March 2004 and testified about the condition of AAA's hymen, indicating possible penetration.
- BBB, the mother of AAA, testified about a change in AAA’s behavior and her findings after AAA ran away from home, including a handwritten letter from AAA that accused CCC of being a "MANYAK" (lewd).
- AAA's testimony was expunged from the record due to the lack of cross-examination, which became a s