Case Summary (G.R. No. 237412)
Charges and Judicial Proceedings
Rodrigo Lapore was charged with rape under Article 266-A of the Revised Penal Code, as amended by Republic Act No. 8353. Following his arraignment on 26 January 1999, where he pleaded not guilty, the trial proceeded with the presentation of both prosecution and defense evidence. The Regional Trial Court (RTC) delivered its verdict on 20 March 2007, convicting Lapore, a decision upheld by the Court of Appeals on 12 October 2009.
The Prosecution's Case
The prosecution presented AAA's testimony, revealing that Lapore sexually assaulted her when she was left alone in her room after her parents had departed. AAA's account involved Lapore entering her room, threatening her with a knife, and engaging in sexual intercourse against her will. AAA's report of the incident to her parents upon their return and subsequent medical examination by Dr. Josieveline M. Abiog-Damalerio corroborated her claims, revealing healed lacerations consistent with rape.
Defense Arguments
Lapore's defense centered on his assertion that he had only known AAA after the incident and that AAA's allegations stemmed from personal vendetta due to his reprimands of her mother. He argued that AAA’s identification of him as the perpetrator was inconsistent and lacked credibility, claiming that AAA was engaged in a romantic relationship with another individual, which he suggested could explain her pregnancy.
RTC Findings
Upon review, the RTC found Lapore guilty of rape, citing the use of intimidation and a deadly weapon, sentencing him to reclusion perpetua and imposing civil and moral damages to the victim. The court emphasized the weight of AAA's testimony alongside medical evidence demonstrating physical injuries indicative of sexual assault.
Court of Appeals Decision
The Court of Appeals confirmed Lapore's conviction but modified the ruling regarding the classification of the crime from qualified to simple rape. It clarified that the aggravating circumstances presented, while proven, did not suffice to elevate the charge because they were not properly alleged in the Information as mandated by Rule 110 of the Rules on Criminal Procedure.
Final Ruling and Affirmation
The Sup
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Case Overview
- This case involves the accusation and subsequent conviction of Rodrigo Lapore for the crime of rape against a thirteen-year-old victim referred to as AAA.
- The conviction was based on the events that transpired in October 1998 in Barangay Berong, Quezon, Palawan.
- Lapore was found guilty by the Regional Trial Court (RTC), with the ruling affirmed by the Court of Appeals.
Jurisdiction and Initial Proceedings
- The events occurred within the jurisdiction of the RTC, Branch 50, Puerto Princesa City.
- A warrant for Lapore's arrest was issued on January 26, 1999, but he remained at large until his arrest on February 11, 2000.
- Lapore pleaded not guilty during his arraignment, leading to a trial on the merits.
Prosecution Evidence
- The victim, AAA, was thirteen years old and illiterate, living with her family in Barangay Berong.
- On October 1, 1998, while her parents were away, AAA was left in the house with her siblings and Lapore, who was a guest and pastor.
- Lapore entered AAA's room, assaulted her, and threatened her with a knife when she attempted to cry out for help.
- Following the incident, AAA disclosed the assault to her parents upon their return, leading to a confrontation with Lapore, who admitted to the act.
- AAA's mother, BBB, confirmed AAA's age with her birth certificate, which was accepted by the defense.
- A medical examination revealed healed lacerations consistent wit