Case Summary (G.R. No. 215195)
Applicable Law
The laws applicable to this case include Articles 266-A and 266-B of the Revised Penal Code, which define and delineate the crime of rape, specifically statutory rape. The elements of qualified rape under Philippine law necessitate a victim under the age of twelve and a relationship by consanguinity to the perpetrator.
Factual Background
AAA testified that on the evening of July 19, 2003, she was in the sala of their residence, along with her three younger sisters, while their mother was away working in Manila. After returning from a drinking spree, accused-appellant removed AAA’s shorts and undergarments and engaged in sexual intercourse with her despite her attempts to resist. Following the assault, AAA reported the incident to a neighbor, Virginia Capote, who assisted AAA in seeking medical examination and filing a police report.
Procedural History
Accused-appellant was arraigned and pleaded not guilty to the charges of qualified rape. After a trial during which AAA provided detailed testimony about the assault, the RTC found him guilty beyond reasonable doubt and sentenced him to reclusion perpetua. The CA affirmed this decision but modified the civil damages awarded to AAA.
Appeals and Contentions
On appeal, accused-appellant contended that the prosecution failed to prove his guilt beyond reasonable doubt and criticized AAA's testimony as insufficiently detailed regarding the act of penetration. He highlighted the absence of testimony describing a push-and-pull motion during the alleged assault.
Legal Principles on Credibility of Witnesses
The Supreme Court reinforced the legal principle that the credibility of the victim is paramount in cases of rape. It underscored that a trial court’s findings on witness credibility deserve great deference, given the court’s unique ability to observe demeanor and behavior during testimony. The Court emphasized that both the RTC and the CA found AAA’s narrative to be credible and compelling.
Elements of Qualified Rape
The Court confirmed that the elements required for a finding of qualified rape were sufficiently established: AAA was eleven years old, and the accused-appellant was her father, fulfilling the statutory requirements. The prosecution demonstrated the relationship between the accused and the victim through AAA’s Certificate of Live Birth and her credible account of the events.
Analysis of Defense and Verdict
The Supreme Court noted that the accused's alibi and claims of AAA's failing
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Case Background
- The case involves accused-appellant Jose Descartin, Jr. y Mercader, who challenges the August 8, 2014 Decision of the Court of Appeals (CA) affirming his conviction for Qualified Rape.
- The Regional Trial Court (RTC) of Davao City had previously rendered a decision on June 13, 2011, convicting him for the crime in Criminal Case No. 52-760-03.
- The Information charged that on or about July 19, 2003, in Davao City, the accused, being the biological father of the 11-year-old victim, AAA, had carnal knowledge of her, which was qualified under the law due to their familial relationship.
Procedural History
- Upon arraignment, the accused-appellant pleaded not guilty.
- The trial ensued, during which the court heard testimonies from both AAA and the accused-appellant.
- The RTC found the accused guilty and sentenced him to suffer the penalty of reclusion perpetua.
- The CA affirmed this decision with modifications regarding the monetary damages awarded to the victim.
Testimonies and Evidence
Victim's Testimony (AAA):
- AAA testified that on the night of July 19, 2003, she was sleeping in the sala with her three younger sisters when the accused arrived home after drinking.
- The accused removed AAA's shorts and panty, attempted to raise her leg, and ultimately succeeded in raping her despite her attempts to resist.
- She de