Case Summary (G.R. No. 28702)
Applicable Law
The legal framework applicable to this case includes the Revised Penal Code of the Philippines and Republic Act No. 8353, known as the Anti-Rape Law of 1997. Given that the decision date of the case is December 4, 2008, the relevant provisions of the 1987 Philippine Constitution also apply.
Summary of Facts
On November 19, 1999, Isang was charged with two counts of rape against AAA. The first count related to an alleged incident in June 1996, while the second count referred to an incident on September 5, 1999. During the trial, AAA testified she had been subjected to sexual abuse by her father from 1994 to 1999. Notably, the trial court found sufficient evidence to convict Isang solely based on the September 5, 1999 incident.
Trial Proceedings
During the trial, the prosecution called witnesses including AAA, her mother BBB, psychologist Dr. Ruby M. Bell, and examining physician Dr. Vladimir Villaseñor. The defense presented no evidence due to Isang's escape from detention. Despite the absence of the defense, the prosecution's evidence was compelling; AAA detailed the sexual assault, emphasizing her father's intimidation during the act and her subsequent silence out of fear.
Judicial Findings
The Regional Trial Court (RTC) determined that the prosecution's presentation of evidence was sufficient to convict Isang of the rape charge relating to the September 1999 incident. On September 24, 2004, the RTC convicted Isang, imposing the death penalty based on the minor status of AAA and their familial relationship, as provided under Article 266-B of the Revised Penal Code.
Appeal Process
Following RTC's decision, the case automatically appealed due to the imposition of the death penalty. Eventually, it was forwarded to the Court of Appeals for intermediate review. On May 30, 2007, the Court of Appeals upheld the RTC's conviction but modified the penalty from death to reclusion perpetua in accordance with Republic Act No. 9346, which prohibits the imposition of the death penalty.
Arguments by Isang
In his appeal, Isang contended that the RTC did not adequately scrutinize AAA's testimony. He specifically highlighted a part of her testimony that purportedly demonstrated confusion regarding the definition of rape, claiming there was no actual vaginal penetration. However, the Court found such arguments misleading, recognizing that AAA’s testimony was otherwise clear regarding the assault.
Court's Rationale
The Supreme Court affirmed the findings of the lower courts, emphasizing that the credible testimony of AAA, corroborated by psychological and medical evidence, supported the conviction. The Court noted that escapes from detention suggest a consciousness of guilt. It also reiterated that AAA's credibility was bolstered by the serious nature of the accusation against her own father, suggesting that no young girl would fabricate such a claim.
Qualification of Circumstances
The Court confirmed that the special qualifying circumstances of minor status and familial relationship were correctly alleged in the charge and sufficiently proven during the trial. Consequently, while the trial court's initial imp
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Case Overview
- This case involves a review of the Decision of the Court of Appeals regarding the conviction of Ignacio Isang y Lagay for the crime of rape against his daughter, AAA.
- The case originated from two counts of rape filed against Isang, with the primary focus on the incident that occurred on September 5, 1999.
- The Court of Appeals modified the Regional Trial Court's (RTC) decision, notably reducing the penalty from death to reclusion perpetua.
Background Information
- Ignacio Isang was charged with two counts of rape involving his daughter, AAA, both filed on November 19, 1999.
- The first count pertains to an incident in June 1996, while the second count focuses on the incident that occurred on September 5, 1999.
- Isang pleaded not guilty, and the cases were jointly tried.
Testimonies and Evidence Presented
The prosecution presented testimonies from several witnesses, notably AAA, her mother BBB, psychologist Dr. Ruby M. Bell, and physician Dr. Vladimir Villaseñor.
AAA's Testimony:
- AAA described a pattern of sexual abuse by Isang from 1994 to 1999, emphasizing the incident on September 5, 1999.
- On that date, AAA was washing clothes when Isang called her inside the house and forced her to lie down, subsequently raping her.
- She testified to her struggles and the fear she felt, stating that Isang warned her not to tell anyone.
BBB's Testimony:
- AAA's mother, BBB, returned from working abroad and, upon discussing child abuse with her sister, prompted AAA to