Case Summary (G.R. No. 94008)
Facts of the Case
On the day of the incident, Marites was returning home from school when Fernandez approached her with an offer of cashew fruits and led her to a secluded area. There, he assaulted her, overriding her lack of consent. After the assault, Marites returned home in distress and reported the incident to her parents, who took her to the hospital. Medical examinations confirmed signs of sexual abuse.
Identification and Investigation Process
Following the incident, a barangay official presented a suspect named Danny Miranda, whose bloodied clothing was found in proximity to the crime scene. However, Marites did not identify Miranda as the perpetrator. Instead, after spotting Fernandez at a public event, she confidently identified him as the assailant to her father. Consequently, law enforcement arranged a police line-up where her identification of Fernandez was consistent.
Defense Arguments and Court Findings
Fernandez's defense relied on denial and alibi, suggesting that Miranda was responsible based on the evidence of his soiled clothing. However, the court found these assertions unconvincing, emphasizing that the unwavering identification by Marites was compelling. The court noted Marites's immediate reporting of the crime and her participation in medical examinations as indicators of her credibility.
Evaluation of Alibi Defense
The court assessed Fernandez's alibi, positing that mere attendance at school did not account for his exact whereabouts at the time of the crime, given that no evidence confirmed his presence in the classroom during the incident. The court ruled that alibi, to be credible, must leave no room for doubt, which was not achieved here.
Rape Definition and Conviction
Under Philippine law, particularly Article 335 of the Revised Penal Code, rape is defined as carnal knowledge of a woman under twelve years of age. The evidence substantiated the claim that Fernandez had committed rape against a minor, meeting the legal definition.
Mitigating Circumstances and Sentencing
Fernandez sought to invoke his minority as a mitigating circumstance, as he was sixteen years old at the time of the offense. The court acknowledged this, stating that the penalty prescribed for the crime of rape was reclusion perpetua, but modified the sentence to a lesser range given his age. It applied the Indeterminate Sentence Law, resulting in a sentence of prision mayor in its minimum and reclusion temporal in its medium period.
Child and Youth Offender Provisions
The prosecution arg
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Case Background
- The case involves an appeal by Edgar B. Fernandez against the decision of the Regional Trial Court, First Judicial Region, Branch 37, Lingayen, Pangasinan.
- The appellant was convicted of the crime of rape against a seven-year-old girl named Marites C. Soriano.
- The trial court’s decision was rendered on October 17, 1989, sentencing Fernandez to Reclusion Perpetua, ordering him to indemnify the victim P20,000.00, and to pay court costs.
Incident Description
- The rape occurred on March 8, 1985, around noon when Marites was walking home after school.
- Fernandez, a sixteen-year-old boy, offered Marites two cashew fruits and led her to a secluded area near the Colegio of Pangasinan Sur.
- He forced Marites to lie down and had carnal knowledge of her without her consent.
Victim's Response
- After the assault, Marites returned home crying and bleeding, immediately informing her parents about the incident.
- Her father took her to Sto. Nino Hospital and subsequently to Pangasinan Provincial Hospital, where a medical report confirmed sexual abuse.
Identification of the Offender
- Initially, barangay authorities presented Danny Miranda as a possible suspect, based on blood-stained clothing he was found with.
- However, Marites did not identify Miranda as her