Case Summary (G.R. No. 127652)
Factual Background
This case involves Oscar M. Dante, charged with the crime of rape against his stepdaughter, Aurora CaAizares. The central incident occurred on March 25, 1996, in Quezon City. The prosecution presented evidence that Dante had been sexually abusing Aurora since she was ten years old. The latest incident escalated as Dante threatened Aurora to secure her compliance, resulting in her eventual disclosure of the abuse to her peers, leading to police intervention.
Testimonies and Evidence
Aurora provided compelling testimony detailing the abuse she suffered, stating that Dante initiated sexual encounters using threats and intimidation. Despite his denial of the charges, medical evidence corroborated Aurora's claims, demonstrating signs of prior sexual abuse. The testimonies included those of family members who were informed about the abuse and medical experts who examined Aurora, providing critical support for her allegations.
Accused-Appellant's Defense
Dante contended that the prosecution failed to establish his guilt beyond reasonable doubt and that the allegations were constructed based on personal biases of Aurora. He argued that the legal definition of rape was not satisfied due to the absence of force or intimidation. He also claimed that the healed lacerations found on Aurora did not align with the timeline of the alleged rape.
Motion for New Trial
Dante filed a Motion for New Trial based on an affidavit from Aurora, indicating a desire for justice and a more accurate version of events. However, the prosecution opposed this motion, highlighting that post-conviction affidavits of retraction are generally viewed with skepticism as they could be influenced by external pressure, thus lacking reliability.
Legal Analysis and Conclusions
The court affirmed the trial court's conviction of Dante for rape, asserting that his moral ascendancy over Aurora significantly contributed to the intimidation she experienced. The judgment clarified that the perception of the victim matters significantly in establishing the presence of intimidation. The court noted that the absence of fresh lacerations does not invalidate rape claims and dismissed Dante's attempts to portray Aurora's character as unsuitable for the severity of the crime.
Sentencing
While affirming the conviction, the Supreme Court modified the penalty imposed on Dante. It determined that since the complaint did not appropriately allege the circumsta
...continue readingCase Syllabus (G.R. No. 127652)
Case Background
- The case is an automatic review of the Decision dated November 27, 1996, by the Regional Trial Court of Quezon City, Branch 76, which found Oscar M. Dante guilty of rape and imposed the death penalty.
- The criminal complaint was filed on March 29, 1996, charging the accused with the crime of rape committed on or about March 25, 1996.
- The complainant, Aurora CaAizares, claimed that the accused used force and intimidation to engage in sexual acts against her will.
Facts of the Case
- Aurora CaAizares lived with her mother and the accused, who is her mother’s first cousin and her live-in partner.
- She regarded the accused as her stepfather, having cohabited since she was eight years old.
- Aurora alleged that the accused first raped her in 1992 when she was ten years old and continued to do so until the last incident on March 25, 1996, when she was fourteen.
- During the last incident, the accused sent Aurora’s younger sister to the store, after which he forcibly removed Aurora's clothing and raped her.
- Aurora reported the incident to a classmate, who subsequently alerted their parents and the police.
Testimonies and Evidence
- Aurora's father, Antonio CaAizares, testified that he learned of the incident through a tabloid article and later took custody of Aurora.
- Dr. Ma. Cristina Freyra conducted a medical examinat