Title
People vs. Jose
Case
G.R. No. 128789
Decision Date
May 24, 1999
A 5-year-old victim was raped by the accused, who was convicted of statutory rape and sentenced to death, with damages awarded for her trauma.

Case Summary (G.R. No. 128789)

Key Dates

The trial court rendered its judgment on December 10, 1996, convicting Renato Caparanga Jose of statutory rape. He subsequently appealed the decision to the higher court.

Applicable Law

The charge against the accused-appellant falls under Article 335 of the Revised Penal Code, as amended by Republic Act No. 7659, which governs the crime of rape and prescribes the imposition of the death penalty for the crime when certain conditions are met, including if the victim is under twelve years of age.

Summary of Facts

The events leading to the trial began on February 6, 1995, when Aimzyl Tria was left home alone while watching television. It was at this time that the accused-appellant coerced her into moving to the master bedroom, where he sexually assaulted her. The assault involved both digital penetration and vaginal penetration with his penis, after which the victim displayed signs of trauma and infection, confirmed by medical examinations. Medical reports revealed the victim was positive for gonorrhea and had sperm present in her vaginal smear, evidencing the assault.

Trial Proceedings

Following the abuse, Aimzyl's mother observed unusual symptoms, including mucus on her daughter's underwear, leading to a conversation in which Aimzyl revealed the details of the assault. Medical examinations at Dr. Priscilla Buenavista's clinic corroborated the abuse with physical findings indicative of sexual molestation.

Verdict of the Trial Court

The trial court found the evidence sufficient to convict Renato Caparanga Jose, citing the direct testimony of the victim and medical evidence. On December 10, 1996, Judge Amelita G. Tolentino sentenced him to death and ordered him to pay moral damages to the victim.

Appeal Arguments

The accused-appellant appealed the verdict, arguing that the prosecution failed to prove his guilt beyond a reasonable doubt, positing that the victim might have been mistaken in identifying him as her assailant. His argument relied on the child’s young age and her statement about a 'Kuya Nat,' whom she claimed to know.

Appellate Court's Analysis

The appellate court reaffirmed the trial court's conviction, underscoring the child's credibility as a witness. It established that the trial court’s assessment of witness credibility was supported by the record, dismissing the accused's claims of mistaken identity as speculative and unsubstantiat

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