Case Summary (G.R. No. 186499)
Case Background
The case centers around accusations of statutory rape involving the accused-appellant, Melecio De Los Santos, Jr. He faced two charges of statutory rape against his niece, AAA. The first charge pertained to an incident that occurred on February 14, 1995, when AAA was only 11 years old. The second charge was for an incident in September 1995. The Regional Trial Court found the accused-appellant guilty of the first count and sentenced him to reclusion perpetua, while the second count resulted in acquittal due to insufficient evidence.
Proceedings and Evidence
At the arraignment on April 18, 2000, the accused-appellant entered a plea of not guilty. The prosecution presented the testimony of AAA, who described the incidents of abuse, stating that the accused threatened her with a knife during the rapes. The testimonies of her sister BBB and their father CCC corroborated AAA's account. Medical evidence presented by Dr. Plaza indicated signs consistent with sexual abuse, including notable injuries found during a physical examination.
Defense and Counterarguments
The accused-appellant denied the charges, asserting he was not present at the location during the events described. He claimed he was attending to his sick adoptive father in Escalante, Negros and provided supporting documentation of the date of his father's death and his marriage certificate to bolster his alibi. However, the court found his alibi unsubstantiated as it did not directly contradict AAA's testimony regarding the rapes.
Trial Court Decision
The trial court ruled that the prosecution had established the guilt of the accused-appellant in Criminal Case No. CBU-51855 beyond reasonable doubt, supported by credible witness testimonies and medical findings. The court acquitted him in the second case due to a lack of evidence. The penalties included civil indemnity, moral damages, and exemplary damages to the victim.
Court of Appeals Ruling
Upon appeal, the Court of Appeals affirmed the trial court’s judgment on August 31, 2007. It held that the discrepancies in witness testimonies were not fatal to the prosecution's case and maintained that the credibility of AAA's account was bolstered by medical evidence. The appellate court found that the accused-appellant failed to present compelling counter-evidence to undermine the prosecution's allegations.
Supreme Court Analysis
The Supreme Court ruled on the appeal, focusing on the application of Article 335 of the Revised Penal Code, which stipulated the criteria un
...continue readingCase Syllabus (G.R. No. 186499)
Case Background
- The case involves an appeal by accused-appellant Melecio de los Santos, Jr. against the decision of the Court of Appeals dated August 31, 2007.
- The appeal follows a conviction by the Regional Trial Court (RTC) of Cebu City, which sentenced the accused to reclusion perpetua for one count of statutory rape against a minor, referred to as AAA.
- The case was filed under Criminal Case Nos. CBU-51855 and CBU-51856, with the first case concerning an incident on February 14, 1995, and the second case on an unspecified date in September 1995.
Charges and Allegations
- The accused was charged with two counts of statutory rape under the Revised Penal Code, specifically Article 335.
- The first information stated that on February 14, 1995, the accused, taking advantage of the victim's age and absence of parental supervision, used intimidation and threats with a knife to engage in sexual intercourse with AAA, who was only eleven years old.
- The second information alleged a similar incident in September 1995, involving the same victim and circumstances of intimidation.
Proceedings in the Trial Court
- During the arraignment on April 18, 2000, the accused pleaded not guilty.
- A pre-trial conference was held, leading to a joint trial of both charges.
- The prosecution presented various testimonies, including that of the victim, her father, and medical experts.
Testimony of the Victim (AAA)
- AAA testified about the details of the first incident where the accused threatened her with a knife and forcibly had sexual intercourse with her.
- She recounted a second incident occurring in September 1995, where the accused again threatened her before committing the act.
- Despite the trauma, AAA did not immediately disclose the abuse to her parents due to fear of the accused's threats