Title
People vs. Echegaray y Pilo
Case
G.R. No. 117472
Decision Date
Jun 25, 1996
Leo Echegaray convicted of raping his 10-year-old daughter; Supreme Court upheld death penalty, citing credible testimony, medical evidence, and moral ascendancy over the victim.

Case Summary (G.R. No. 117472)

Procedural Posture

The Regional Trial Court (Quezon City, Branch 104) convicted the accused of rape and sentenced him to death under RA 7659, together with civil damages and accessory penalties. The trial court’s judgment dated September 7, 1994 was subject to automatic review by the Supreme Court, which sat en banc to consider the appeal by the accused-appellant.

Factual Summary (Prosecution)

The prosecution’s narrative, derived from the victim’s testimony and other evidence, is that during April 1994 the accused, her father/stepfather/common‑law spouse of the mother, forcibly raped his ten‑year‑old daughter on multiple occasions (up to five times) while the mother was away. The victim described being dragged into a room, stripped of her underwear, placed on the floor, and having the accused insert his penis into her genitalia, causing intense pain. The accused allegedly threatened to kill the victim’s mother to ensure silence. The victim later reported the assaults to her grandmother and mother, executed an affidavit, and was subjected to medico‑legal examination which showed healed lacerations of the hymen and vaginal wall consistent with traumatic injury.

Defense Theory and Evidence

The defense advanced a theory of fabrication and motive: that the victim’s grandmother, motivated by greed for a disputed NHA lot (purportedly co‑owned by the accused and the grandmother’s live‑in partner), coached the child to file the rape charge to eliminate the accused as co‑owner. The defense produced testimony from the mother, the accused, and other witnesses asserting alternative explanations: alleged prior family conflicts, the victim’s purported sexualized behavior (masturbation, exposure to sex materials), and an alibi for the accused supported by a “Contract of Services” indicating the accused was painting in Parañaque during the relevant period. The accused also claimed biological impossibility based on the asserted extraordinary size of his penis.

Trial Court Findings and Credibility Determinations

The RTC found the victim’s testimony straightforward, detailed, and credible, noting emotional distress displayed during narration and the lack of a demonstrable motive to fabricate. The court rejected the defense’s motive theory and treated the mother’s and grandmother’s conduct as insufficient to impeach the victim’s credibility. The trial court also regarded the alibi as uncorroborated and weak, while accepting the medico‑legal evidence as consistent with the victim’s account.

Issues Raised on Appeal

The accused-appellant contended that: (1) the grandmother had a sinister motive to fabricate the charge for land consolidation; (2) the medical findings (healed lacerations at 3 and 7 o’clock) were inconsistent with the alleged act, especially given the accused’s claimed penile size; and (3) the alibi was improperly disregarded, with the Contract of Services allegedly proving his absence from the scene.

Legal Standards Applied for Rape Cases Involving Minors

The Court reiterated established principles: accusations of rape can be easily made but difficult to disprove; the testimony of a complainant in rape cases must be scrutinized with caution because of the typically private nature of the offense; nevertheless, when a young victim has no apparent motive to lie and gives coherent, detailed testimony corroborated by medical evidence, her account is entitled to great weight. The Court also relied on jurisprudence recognizing (a) the elasticity of the female genitalia and that full penetration is not necessary to constitute rape, (b) the lack of necessity of a broken hymen to sustain conviction, and (c) that minor inconsistencies in details do not necessarily destroy a witness’s overall credibility.

Analysis of Alleged Motive to Fabricate (Property Dispute)

The Court found the motive theory speculative and insufficiently persuasive. Although documents in the record indicated the disputed lot’s co‑ownership, the Court concluded that it was not plausible that a grandmother would induce her ten‑year‑old granddaughter to fabricate a rape charge against her own father solely to consolidate property rights. The absence of credible, concrete proof of such a conspiracy led the Court to uphold the trial court’s acceptance of the victim’s testimony as free from a demonstrable motive to lie.

Analysis of Inconsistencies in Witness Testimonies

The Court examined minor discrepancies (e.g., whether the accused was naked when he dragged the victim inside, slight variations in the words allegedly uttered, or differing accounts of how the grandmother first learned of the abuse). It characterized these as immaterial inconsistencies that do not undermine the core, coherent account of the sexual assaults. The Court reiterated that minor lapses of memory or slight variations are expected and may even support the genuineness of testimony rather than suggest collusion.

Medical Evidence and the “Penile Size” Argument

The accused’s claim that his alleged large penile size made the alleged assaults impossible was deemed self‑serving and lacking probative support in the record. The Court relied on medico‑legal examination showing healed lacerations consistent with the timeframe of the reported acts and invoked authorities establishing that the vaginal canal is distensible and that injuries of varying degrees are consistent with sexual assault of a minor. The Court emphasized that partial penetration or forceful contact suffices to constitute rape; complete rupture or extensive laceration i

...continue reading

Analyze Cases Smarter, Faster
Jur helps you analyze cases smarter to comprehend faster, building context before diving into full texts. AI-powered analysis, always verify critical details.

About Privacy Terms