Case Summary (G.R. No. 123599)
Factual Background
On November 8, 1994, while Agapito's partner, Rosario, had temporarily left the home following a domestic quarrel, Agapito called Ma. Cristina into the bedroom, brandishing a knife. He forced her to undress and raped her. It was later revealed that this was not an isolated incident, as Ma. Cristina testified that she had been sexually abused by her father multiple times previously. Rosario learned of the incident upon returning home and immediately reported it to the authorities.
Testimonies
The prosecution’s case largely rested on the testimony of Ma. Cristina, who detailed the assault with clarity. She described the threats made by Agapito and corroborated her testimony with medical findings from Dr. Rosaline Casidone, who discovered healed lacerations on her hymen. The accused-appellant, in contrast, claimed the charges were fabricated retaliation from Rosario, disputing the incidents of physical abuse and the identified knife as evidence.
Defense Arguments
Agapito's defense contended that inconsistencies in Ma. Cristina’s testimony undermined her credibility. He cited differences between her statements made at trial and her earlier sworn declarations, suggesting they indicated the fabrication of the charges. Furthermore, he argued the medical findings of pre-existing hymenal lacerations and a lack of evident physical trauma, asserting this did not qualify as rape under the circumstances presented.
Trial Court's Findings
The trial court affirmed the credibility of Ma. Cristina’s narration, dismissing the claimed inconsistencies as collateral and minor. The court ruled that Agapito's moral ascendancy and influence over his daughter constituted sufficient intimidation, independent of physical violence, thus meeting the threshold for rape as stipulated by law.
Supreme Court Review
In the Supreme Court, while affirming the guilt of Agapito Flores for rape, the Court acknowledged an error in the sentencing. It observed that the information did not include the relationship between the accused and the victim, which is crucial under RA 7659 for imposing the death penalty. The court modified the original decision, setting aside the death penalty in favor of reclusion perpetua, stating that the accused should face a penalty that is lawful and just.
Civil Liabilities
The Supreme Court also addressed the civil liabilitie
...continue readingCase Syllabus (G.R. No. 123599)
Case Background
- The case involves Agapito V. Flores, who was charged with the crime of Rape in Criminal Case No. Q-94-99462.
- The Regional Trial Court of Quezon City sentenced him to death for the crime committed on November 8, 1994, against his 13-year-old daughter, Ma. Cristina.
- The incident occurred when Agapito, armed with a knife, forced Ma. Cristina to undress and subsequently raped her.
Facts of the Case
- Ma. Cristina, the eldest of four children, lived with her parents, Agapito and Rosario Flores, in Quezon City.
- On the evening of November 7, 1994, Agapito and Rosario had a violent quarrel, leading Rosario to leave the house for safety.
- The following morning, Agapito ordered all the children to leave the house except Ma. Cristina, claiming he wanted to talk to her.
- Once alone, Agapito threatened Ma. Cristina with a knife, compelling her to undress before he raped her, inflicting physical and emotional trauma.
- After the incident, Ma. Cristina's mother reported the crime to the police, leading to a medical examination that revealed healed hymenal lacerations.
Testimonies Presented
Ma. Cristina's Testimony:
- Described how Agapito threatened her with a knife and forced her to undress.
- Recounted the details of the assault, including the duration and the pain she experienced.
- Stated that this was not the first incident of rape; she