Case Summary (G.R. No. 117472)
Factual Background
In April 1994, while the victim’s mother was away, Leo Echegaray forcibly dragged his ten-year-old daughter into a room at their residence in Barangay San Antonio, Quezon City. He removed her garments, inserted his penis into her vagina without consent, and repeated the act on five separate occasions. The victim suffered intense pain, exhibited lacerations of the hymen and vaginal walls, and was threatened with violence if she disclosed the abuse.
Procedural History
Rodessa reported the assaults to her grandmother, who in turn assisted in filing a formal rape complaint on July 14, 1994. The RTC of Quezon City, after a marathon hearing, convicted the accused on September 7, 1994, sentenced him to death under RA 7659, awarded P50,000 in damages, and imposed accessory penalties. Under law, the death penalty judgment was subject to automatic Supreme Court review.
Issues on Appeal
- Alleged malicious conspiracy by the victim’s grandmother to fabricate the rape charge for property-related motives.
- Claim that lacerations at 3 and 7 o’clock could not have been caused by the accused’s alleged genital size.
- Assertion of an alibi supported only by a painting contract, without corroborating witnesses.
Prosecution Evidence
The victim provided a detailed, consistent account of five separate assaults, including verbatim statements allegedly uttered by the accused. A medico-legal officer confirmed healed lacerations of the hymen and vaginal walls consistent with the alleged dates. No evidence of bad faith or coaching was shown.
Defense Evidence
The accused and his witnesses claimed the charge was concocted by the grandmother to secure sole ownership of an NHA-Madrigal housing lot. He asserted an alibi—painting work in Parañaque—and argued physical impossibility based on his genital size. The mother testified that the victim was driven by a false attempt-homicide claim, later converted to rape. A babysitter and another relative testified as to the victim’s purported sexual precocity.
Credibility and Motive Analysis
The Court held that the victim, a child of tender years, had no plausible motive to fabricate the story. Minor discrepancies in dress and exact words uttered did not undermine her core testimony. Jurisprudence requires extreme caution in rape cases but also recognizes that young victims seldom invent such accounts, especially when willing to undergo public examination and trial.
Physical Evidence Assessment
Self-serving claims about genital size lacking objective proof were given no weight. Medical testimony established that the hymenal and vaginal membranes are elastic, and the presence of healed lacerations within the relevant period corroborated the victim’s narrative. Full penetration is not required to constitute rape where force and injury are evident.
Alibi Defense and Corroboration
The contract of service showing a painting engagement did not establish the accused’s presence elsewhere at the critical times and lacked independent witness corroboration. Positive
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Facts
- The victim, Rodessa Echegaray, was a ten-year-old fifth grader living with her parents and four younger siblings in Quezon City.
- In April 1994, while the mother was away gambling, the accused-appellant, Rodessa’s father/stepfather, ordered her brothers out of the house.
- He then dragged Rodessa into a room, removed her panties and his underwear, and forcefully inserted his penis into her vagina.
- Rodessa cried out in pain; the appellant threatened to kill her mother if she spoke.
- The assault recurred a total of five times under similar circumstances.
- After the fifth assault, Rodessa confided in her grandmother, who informed the mother; they reported the crime to the barangay captain, executed an affidavit, and procured a medico-legal examination.
- Medico-legal Report No. M-0980-94 by Dra. Ma. Cristina B. Freyra showed healed lacerations of the hymen consistent with recent trauma.
Procedural History
- Complaint filed July 14, 1994, alleging rape of a minor under Article 335, RPC, aggravated by the parent-child relationship.
- Arraigned August 1, 1994; appellant pleaded “not guilty.”
- Regional Trial Court, Quezon City, Branch 104, after marathon hearings, found appellant guilty beyond reasonable doubt of rape aggravated by parenthood and sentenced him to death under RA 7659, plus P50,000.00 damages and accessory penalties.
- This decision was automatically reviewed by the Supreme Court En Banc.
Prosecution Evidence
- Victim’s direct testimony describing the assault in detail, her pain, the appellant’s threats, and his repeated bestial acts.
- Grandmother’s testimony corroborating Rodessa’s account and reporting procedure.
- Medico-legal findings of hymenal lacerations dated to April 1994.
- Consistent statements in affidavit and trial testimony, without ill motive attributed to the ten-year-old complainan