Case Summary (G.R. No. 206972)
Factual Background
The case revolves around the tragic kidnapping and subsequent rape of a 5-month old baby girl identified as AAA. On February 20, 2000, the infant was left in the care of her older sister, CCC, while her mother, BBB, went to boil water at her mother’s house. Upon returning, BBB discovered that AAA was missing. A neighbor reported seeing an ice cream vendor carrying a baby around the time AAA disappeared. A cargo truck driver later witnessed a man abusing a baby in a plaza, confirmed to be AAA. The police were alerted and subsequently found AAA in a distressed state, prompting them to apprehend the accused-appellant, Pamuel A. Magno.
Trial Court Proceedings
During trial, the prosecution presented evidence linking Magno to the crime, primarily relying on the testimony of the eyewitness, the cargo truck driver, who identified him as the perpetrator. The Regional Trial Court ruled on September 3, 2002, that Magno was guilty of the special complex crime of kidnapping with rape, imposing the death penalty and ordering him to pay damages to the victim.
Court of Appeals Decision
On appeal, the Court of Appeals upheld the conviction but modified the sentence to reclusion perpetua without eligibility for parole. This adjustment was due to the prohibition against the death penalty as mandated by Republic Act No. 9346. The appellate court also increased the amounts awarded for civil indemnity, moral damages, and exemplary damages to AAA.
Arguments of the Accused-Appellant
Magno contended that the prosecution failed to demonstrate his guilt beyond a reasonable doubt. He challenged the evidence from the eyewitness, arguing there was no direct proof of carnal knowledge and no evidence of his intent to restrain AAA's liberty necessary for a kidnapping charge. He suggested that the prosecution only established grounds for a lesser charge of rape without the aggravating factor of kidnapping.
Supreme Court Ruling
The Supreme Court firmly affirmed the appellate court’s decision, finding that the evidence, including the eyewitness testimony and medical findings, established Magno's guilt beyond reasonable doubt for both kidnapping and rape. It confirmed that the essential elements of kidnapping—specifically being a private individual who illegally deprived a minor of liberty—were adequately proven.
Medical Evidence
The medical evidence demonstrated that AAA sustained serious injuries, including a lacerated hymen, consistent with the rape allegations. This evidence confirmed the occurrence of sexual assault and provided critical support for the prosecution's case against Magno.
Final Judgment and Damages
The Supreme Court officially modified th
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Case Overview
- This case involves the review of the Decision rendered by the Court of Appeals affirming the Regional Trial Court's (RTC) ruling in Criminal Case No. 2000-02-160.
- The accused-appellant, Pamuel A. Magno, was charged with the crime of kidnapping with rape against a 5-month-old infant, referred to as AAA.
Factual Background
- On February 20, 2000, the mother of the victim, BBB, left her infant daughter AAA in the care of her eldest daughter, CCC, while she attended to some chores.
- Upon BBB's return, AAA was missing, prompting an investigation.
- A neighbor reported seeing an ice cream vendor with a baby, which led to police involvement.
- A cargo truck driver witnessed the accused committing acts of abuse against the child in Plaza Libertad, confirming that the infant's private parts were bloodied.
- Police discovered AAA abandoned on a bench in the plaza and subsequently located and arrested accused-appellant in Barangay 37, based on the driver's identification.
Trial Court Proceedings
- The RTC rendered a Decision on September 3, 2002, finding Magno guilty of kidnapping with rape.
- The court applied Articles 267, 266-A, and 266-B of the Revised Penal Code, sentencing Magno to death and ordering him to pay damages to the victim.
Appellate Court Ruling
- The Court of Appeals upheld the RTC's decision, modify