Case Summary (G.R. No. 116729)
Facts of the Case
On January 22, 1992, at approximately 7:15 PM, Jennifer Soriano was en route to a neighbor's house to watch television. While near the residence of Belen Casandig, she was intercepted by Marlon Lerio, who forcefully covered her mouth, carried her to a nearby area with piles of cogon grass, and sexually assaulted her. Despite her attempts to escape, she was assaulted until the noise of her parents calling her name prompted Lerio to release her. Evidence collected included a headband belonging to the victim and testimonies from local authorities who investigated the matter shortly after it occurred.
Charges and Trial Proceedings
On June 10, 1992, Lerio was charged with statutory rape under Article 335 of the Revised Penal Code. The prosecution presented witnesses including the barangay captain, the victim’s mother, the victim herself, and a health officer. The defense presented only Lerio, who claimed to have spent the evening with relatives and denied any sexual encounter, suggesting that the charges arose from his innocent kiss on the victim.
Decision of the Trial Court
On July 7, 1994, the trial court convicted Marlon Lerio of statutory rape and imposed the penalty of reclusion perpetua, along with ordering him to pay the victim P50,000.00 in moral damages. The court found the testimonies of the prosecution witnesses credible and substantial, particularly the victim’s unwavering account of the events.
Appellant's Arguments
In his appeal, Lerio contended that the trial court erred in accepting the prosecution's evidence as credible, claiming inconsistencies and lack of physical evidence to corroborate the testimony of assault. He emphasized the medical findings, which showed no physical trauma, arguing that this undermined the prosecution's assertion of guilt beyond a reasonable doubt.
Prosecution's Counterarguments
The Office of the Solicitor General defended the trial court's decision, arguing that legal precedent allows for a conviction of rape without physical evidence such as hymenal rupture. Furthermore, they asserted that the integrity of the victim’s testimony should not be undermined simply due to the absence of anatomical damage and highlighted the societal stigma that would accompany a false allegation of such a serious crime.
Analysis of Credibility and Legal Standards
The appellate court acknowledged the trial court’s discretion in assessing witness credibility, stating that findings from the trial court deserve great respect unless there is clear evidence of mistake or abuse of discretion. The court underscored that a victim’s credible testimony can be sufficient for conviction in rape cases, regardless of additional corroborative evidence. The prosecution's arguments concerning the absence of violent resistance in the case of a minor under twelve years of age were also highlighted, indicating that statutory rape does not necessitate proof of force or intimidation.
Conclusion on Conviction and Penalty
Ultimately,
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Case Overview
- This case involves the appeal of Marlon Lerio against his conviction for statutory rape by the Regional Trial Court of Tayug, Pangasinan.
- The court imposed a sentence of reclusion perpetua along with an order for Lerio to pay P50,000.00 in moral damages to the victim, Jennifer M. Soriano.
- The incident occurred on January 22, 1992, when the victim was 11 years old.
Facts of the Case
- Marlon Lerio, 19 years old, was accused of sexually assaulting 11-year-old Jennifer Soriano in the evening of January 22, 1992.
- The victim was on her way to watch television when Lerio intercepted her, covered her mouth, and carried her to a secluded area with piles of dried cogon grass.
- Despite her attempts to resist, Lerio proceeded to remove her underwear and sexually assaulted her.
- The incident was reported by Jennifer's father, Arsenio Soriano, to the barangay captain, Floro Volante, who testified about the crime scene and the victim's condition.
- The victim's mother, Estrelita Soriano, corroborated her daughter’s account and observed physical signs of assault.
Proceedings and Evidence
- The formal charge against Lerio was filed on June 10, 1992, under Article 335 of the Revised Penal Code.
- During the trial, the prosecution presented multiple witnesses, including the victim, her mother, the barangay captain, and a medical officer, Dr. Perfecto