Case Summary (G.R. No. 228248)
Nature of Charges
De Guzman was charged with two counts of Qualified Rape under Article 266-A, in relation to Article 266-B of the Revised Penal Code (RPC). The first charge, Criminal Case No. 11-0539, alleged that he raped AAA, an eight-year-old minor, in 2003. The second charge, Criminal Case No. 11-0541, covered acts of rape committed between 2006 and 2010 when AAA was aged eleven to fifteen.
Testimonies and Evidence
AAA testified that her first sexual assault occurred at the age of eight when De Guzman lured her into a secluded area of their home and proceeded to rape her. Following the assault, De Guzman warned AAA to remain silent, instilling fear for her family's safety. The sexual assaults continued for several years, only disclosed to her aunt, CCC, years later. CCC corroborated AAA's testimony, confirming the girl's account of the sexual abuse. A medico-legal examination conducted by Dr. Editha Martinez confirmed physical injuries consistent with sexual assault.
Defense and Counterarguments
De Guzman denied the allegations, providing a defense of alibi and denial, asserting he was in Pangasinan during the time of the first reported assault, and claiming he never found himself alone with AAA in the subsequent years. De Guzman’s wife, BBB, also testified in support of his denial, asserting AAA's claims were untrue and attributing ill motive to her.
Trial Court’s Findings
The Regional Trial Court (RTC) found compelling evidence of De Guzman’s guilt beyond reasonable doubt. The court noted AAA's clear and emotionally charged testimony and found no substantial motive for her allegations, rendering her claims credible. Consequently, De Guzman was convicted of two counts of Qualified Rape and sentenced to reclusion perpetua for each count, along with the requirement to pay damages to AAA.
Court of Appeals Ruling
Upon appeal, the Court of Appeals affirmed the RTC's decision with modifications, increasing the damages awarded to AAA, which included civil indemnity, moral damages, and exemplary damages. The appellate court reiterated the substantial evidence supporting AAA’s claims and underscored the legal relevance of moral ascendancy as a factor that obscured the victims' ability to resist.
Legal Principles
The ruling reaffirmed the provisions in the Revised Penal Code regarding Qualified Rape, which includes the element of moral ascendancy, especially concerning step-parents. Furthermore, it clarified that the sp
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Case Background
- The case is an appeal from the Decision of the Court of Appeals (CA) dated September 24, 2015, in CA-G.R. CR-HC No. 06284.
- The CA affirmed with modifications the Decision of the Regional Trial Court (RTC) of Las Piñas City, Branch 199, dated June 17, 2013.
- The RTC found accused-appellant Romeo De Guzman y De Castro (De Guzman) guilty of two counts of Qualified Rape under Article 266-A, in relation to Article 266-B, of the Revised Penal Code (RPC).
Charges and Information
- Two sets of Information were filed against De Guzman:
- Criminal Case No. 11-0539: Allegation of raping AAA, an 8-year-old minor, in 2003 using force, threats, and moral ascendancy as her step-parent.
- Criminal Case No. 11-0541: Allegation of raping AAA again between 2006 to 2010 when she was between 11 to 15 years old, also under similar circumstances.
Testimonies and Evidence
- Victim's Testimony:
- AAA testified that De Guzman first sexually assaulted her when she was 8 years old, leading her to a secluded area, removing her clothes, and committing the act.
- After the assault, De Guzman warned AAA to remain silent for fear of her family's safety.
- AAA confided in her aunt, CCC, regarding the abuse, which continued for several years.
- Corroborative Testimony:
- CCC corroborated AAA's account, affirming the victim's disclosures.
- Medical Evidence:
- Dr. Editha Martinez confirmed physical evidence of abuse through a Medico-Legal R