Case Summary (G.R. No. 69870)
Factual Background
In August 2004, Eulalio lured AAA to his home under the threat of kidnapping her siblings. Once inside, he undressed AAA and sexually assaulted her. Despite resistance, he proceeded to rape her through intimidation. Following a month of silence due to fear, AAA was again summoned by Eulalio, leading to further acts of lasciviousness, which were interrupted by AAA’s parents. A medical examination confirmed signs of trauma consistent with the prior sexual assault.
Charges and Proceedings
Two separate Informations dated September 7, 2004, were filed against Eulalio, charging him with rape in relation to Republic Act No. 7610, which focuses on the protection of children against abuse, exploitation, and discrimination. During his arraignment, Eulalio pleaded not guilty. The prosecution presented compelling evidence, including AAA's birth certificate and corroborative witness testimonies, detailing Eulalio's actions.
Ruling of the Regional Trial Court (RTC)
In a decision dated August 23, 2012, the RTC convicted Eulalio of statutory rape and acts of lasciviousness, emphasizing the victim's age and the use of intimidation. The RTC's ruling highlighted the absence of a defense from Eulalio, who waived his right to present evidence, thereby tacitly acknowledging the prosecution’s proof.
Appeal to the Court of Appeals (CA)
Dissatisfied with his conviction, Eulalio appealed to the CA, claiming the prosecution failed to establish his guilt beyond a reasonable doubt. However, the CA reaffirmed the RTC's decision, substantiating the evidence of statutory rape and acts of lasciviousness while modifying the monetary awards.
Legal Framework
The applicable law includes Article 266-A of the Revised Penal Code concerning rape and Article 336 regarding acts of lasciviousness, both of which establish the conditions for conviction. Statutory rape does not necessitate proof of consent or the victim's physical resistance if the victim is under twelve years old.
Court's Ruling on Guilt
The Supreme Court upheld the lower courts' findings, confirming the elements constituting statutory rape were met: AAA's age and Eulalio's carnal knowledge of her under coercive threats. The Court asserted the standard for acts of lasciviousness was also satisfied, highlighting that threats to AAA were sufficient to establish moral ascendancy.
Modifications on Sentencing
The Supreme C
...continue readingCase Syllabus (G.R. No. 69870)
Case Overview
- The case revolves around the appeal of Bernabe Eulalio y Alejo (Accused-Appellant) against the Decision of the Court of Appeals (CA) affirming his conviction for statutory rape and acts of lasciviousness by the Regional Trial Court (RTC) of Malabon City.
- The RTC's ruling was based on incidents involving an 11-year-old girl (referred to as AAA) and occurred in August and September of 2004.
Facts of the Case
- In August 2004, AAA was playing outside when Eulalio summoned her to his home, threatening to kidnap her sibling if she did not comply.
- At Eulalio's home, he undressed AAA and, despite her resistance, threatened her again and proceeded to commit sexual acts against her will.
- In September 2004, Eulalio summoned AAA again, and while he did not undress her this time, he kissed her in a compromising position, which was witnessed by AAA's father, BBB.
- The incidents were reported to the authorities, leading to medical examinations that revealed signs of trauma consistent with sexual abuse.
Charges and Arraignment
- Eulalio was charged with rape and acts of lasciviousness under Republic Act No. 7610.
- During his arraignment, Eulalio pleaded not guilty to the charges.
Ruling of the Regional Trial Court (RTC)
- The RTC found Eulalio guilty of statutory rape and acts of lasciviousness, stating that:
- AAA's age (11 years) eliminated the necessity to prove force or intimidation i