Case Summary (G.R. No. 181473)
Factual Antecedents
Three separate informations were filed against the appellant, charging him with:
- Criminal Case No. 6572 for Qualified Rape: Occurred on August 22, 2002, involving forced carnal knowledge under conditions of moral ascendancy due to relationship and the victim's minority.
- Criminal Case No. 6573 for Sexual Abuse: Took place on August 21, 2002, where the appellant was accused of lasciviously touching his daughter.
- Criminal Case No. 6574 for Qualified Object Rape: Occurred on October 9, 2002, when the appellant allegedly inserted his finger into the victim's genitalia.
Version of the Prosecution
The prosecution's narrative indicates that while the mother and siblings of aAAAa were away, the appellant engaged in sexually abusive acts against her. The specific incidents included fondling and forced intercourse, supported by findings from a physical examination indicating non-virginity and psychological trauma.
Version of the Defense
The appellant denied all allegations, asserting he was not alone with aAAAa during the time of the alleged offenses. He presented an alibi involving family activities but was unable to disprove the prosecution's timeline. Furthermore, he suggested that the accusations arose from marital strife.
Ruling of the Regional Trial Court
The RTC found the testimony of aAAAa credible and corroborated by medical evidence. The court dismissed the appellant’s denial as unsubstantiated. The RTC imposed the following penalties:
- Criminal Case No. 6572: Death for qualified rape.
- Criminal Case No. 6573: An indeterminate sentence for sexual abuse.
- Criminal Case No. 6574: Initially death for the object rape but later modified to a non-death penalty.
Ruling of the Court of Appeals
The Court of Appeals affirmed the RTC's decision, emphasizing the consistency and credibility of aAAAa's testimony over the appellant's denial. The appellate court concluded that the prosecution proved the appellant's guilt beyond a reasonable doubt.
Assignment of Errors
The appellant's appeal reiterated claims of being denied the presumption of innocence and alleged inconsistencies in the victim's testimony. He argued that these inconsistencies should lead to his acquittal.
Our Ruling
The Supreme Court upheld the findings below, reaffirming that minor inconsistencies in aAAAa's testimony did not negate the core elements of the crime, which included her detailed accounts of the assaults and corroborating medical evidence.
Applicable Law
Under Republic Act (RA) No. 8353, which amended the Revised Penal Code, the definition of rape includes both sexual intercourse and acts of sexual assault that exploit the victim's vulnerability, particularly for minors. The court applied the provisions of RA 7610 concerning child sexual abuse in determining the appropriate penalties.
The Proper Penalty
In light of
...continue readingCase Syllabus (G.R. No. 181473)
Case Overview
- This case involves the conviction of Doney Gaduyon y Tapispisan for the crimes of qualified rape, qualified object rape, and sexual abuse committed against his 12-year-old daughter on three separate occasions.
- The decision being appealed is from the Court of Appeals (CA), affirming the earlier ruling of the Regional Trial Court (RTC) in Criminal Case Nos. 6572-74 dated January 18, 2006.
Factual Antecedents
- Three criminal informations were filed against the appellant for the following crimes:
- Criminal Case No. 6572: Qualified Rape occurring on August 22, 2002, where the appellant allegedly had carnal knowledge of his daughter against her will.
- Criminal Case No. 6573: Sexual Abuse occurring on August 21, 2002, involving lewd conduct where the appellant fondled his daughter's breasts.
- Criminal Case No. 6574: Qualified Object Rape occurring on October 9, 2002, where the appellant allegedly inserted his finger into his daughter's genitalia.
Version of the Prosecution
- The appellant was left alone with the victim, aAAAa, while the rest of the family attended a wake.
- On August 21, 2002, the appellant fondled aAAAa and threatened her not to disclose the act.
- On August 22, 2002, he forcibly had sexual intercourse with aAAAa, causing her pain and distress.
- On October 9, 2002, he inserted his finger into her vagina while she was sleeping and again threatened her to remain silent.
- The victim's mother suspected wrongdoing and later reported the incidents to authorities after aAAAa disclosed the abuse to her teacher.