Case Summary (G.R. No. 183827)
Factual Antecedents
Enerio Ending y Onyong faced charges based on three separate Informations filed against him, detailing incidents of rape that occurred on different dates in 2000 and 2001. The allegations describe that, on specified dates, the accused raped his daughter, aAAAa, who was 15 years old at the time. The Informations highlighted that the acts were committed through threats, intimidation, and physical force. Upon arraignment on April 3, 2001, he pleaded not guilty to all charges.
Version of the Prosecution
The testimony of the victim, aAAAa, provided a detailed account of the sexual assaults. She recounted how her father abused her on multiple occasions under threats of violence and intimidation. The first incident occurred when he forcibly entered her room and raped her, and subsequent assaults were described with similar brutality. After enduring threats and fear, aAAAa eventually disclosed the incidents to her classmates and a teacher, leading to police intervention and a medical examination, which confirmed signs of previous sexual trauma.
Version of the Defense
In his defense, Enerio claimed that the accusations were unfounded and rooted in ill motive, emphasizing a past incident where he reprimanded aAAAa for seeing her boyfriend. He suggested that her allegations were fabricated, citing the fact that she lived with her grandparents during the time of the alleged rapes. His testimony lacked supporting evidence, demonstrating merely a denial of the charges without credible corroboration.
Ruling of the Regional Trial Court
The RTC rendered a decision on October 17, 2001, convicting Enerio of three counts of rape, driven by a firm belief in the credibility of aAAAa's testimony. The court emphasized the gravity of the offenses, sentencing him to death for each count and awarding damages to the victim.
Ruling of the Court of Appeals
Upon appeal, the Court of Appeals affirmed the RTC ruling on September 28, 2007, although it modified the sentence to reclusion perpetua instead of death, aligning with the legal prohibitions against the death penalty at the time. The appellate court maintained that Enerio had executed his criminal intentions through intimidation and force while increasing the amounts of damages awarded to the victim.
Legal Issues Raised
In his appeal, Enerio contended that the RTC erred in concluding that he was guilty beyond a reasonable doubt due to alleged issues regarding aAAAa’s credibility and his presence during the commission of the crimes. He sought to undermine the strength of the prosecution's evidence, asserting possible motivations behind his daughter’s claims.
Our Ruling
The Court found no merit in Enerio's arguments, reaffirming the principle that mere denial and alibi are not persuasive without substantial evidence. It highlighted that aAAAa's consistent and credible testimony outweighed Enerio's defenses. The Court also noted that the physical proximity to where the victim lived did not absolve him from being a viable suspect in the crimes. Furthermore, motivations regarding familial discord did not undermine the compelling nature of aAAAa's disclosures, which were consistent with the trauma suffered.
Qualifying Circumstances and Penalty
The presence of both the victim's minority and her re
...continue readingCase Syllabus (G.R. No. 183827)
Case Overview
- The case revolves around Enerio Ending y Onyong, who was accused of committing incestuous rape against his own daughter, referred to as aAAA.a.
- The judgment includes a review of the credibility of testimonies and the weight given to the findings of the trial court.
Procedural History
- Appellant Enerio Ending y Onyong appealed the decision of the Court of Appeals (CA) which affirmed the Regional Trial Court (RTC) ruling that found him guilty of three counts of rape.
- The RTC’s decision was rendered on October 17, 2001, and the CA modified the decision on September 28, 2007.
Factual Antecedents
- Enerio was indicted through three separate Informations for raping his daughter aAAA.a, who was 15 years old at the time of the incidents.
- The specific incidents occurred on January 18, 2000, and January 2, 2001, as detailed in the Informations.
Version of the Prosecution
- The victim, aAAA.a, testified about the first incident of sexual assault, describing how her father entered her room, threatened her, and forced her into sexual acts.
- Subsequent assaults occurred in different locations, including a copra drier and a pasture land, where the same pattern of threats and force was repeated.
- After enduring these assaults, aAAA.a initially remained silent due to fear of her father's threats but eventually disclosed the incidents to her classmates and teacher.
Version of the Defense
- Enerio, the appellant, testified that he loved his daughter and could not com