Case Summary (G.R. No. 172068)
Background of the Case
The Regional Trial Court (RTC) of Pinamalayan filed two separate Informations for rape against Mangubat, leading to Criminal Case Nos. P-5788 and P-5789. The first incident allegedly occurred in 1997 when AAA was ten years old, and the second on June 13, 1998, when she was eleven years old. The initial decision made by the RTC found Mangubat guilty of qualified rape, imposing the death penalty for each count, which was later modified by the Court of Appeals (CA), reducing the charges to simple rape and sentencing him to reclusion perpetua.
Evidence Presented
The prosecution's case relied heavily on the testimonies of AAA and Dra. Adelaida Malaluan, the municipal health officer who conducted the physical examination of AAA after she reported the rapes. AAA recounted that during both incidents, Mangubat used force and intimidation to compel her into sexual acts. Conversely, Mangubat and his common-law wife BBB provided a defense consisting of denial, claiming AAA's accusations were retaliatory.
Trial Court’s Decision
In March 2002, the RTC found Mangubat guilty beyond a reasonable doubt of two counts of qualified rape based on AAA's credible testimony and the special qualifying circumstances of her age and relationship with the accused. The court sentenced him to death and ordered him to pay indemnification to AAA.
Court of Appeals’ Modification
On January 23, 2006, the CA affirmed the RTC's decision but modified the charges to simple rape, citing the failure to establish the alleged grandfather-granddaughter relationship necessary for a qualified rape conviction. The CA sentenced Mangubat to reclusion perpetua for each count instead of death and increased the civil indemnity to include moral damages.
Appeal to the Supreme Court
Mangubat subsequently appealed to the Supreme Court, insisting on his innocence and claiming insufficient evidence for his conviction. The Supreme Court reiterated its deference to the trial court’s assessment of witness credibility and corroborated AAA’s testimony with the medical findings of penetration as sufficient to establish the crime of rape.
Legal Analysis of the Findings
The Supreme Court emphasized that full penetration is not required to constitute rape; even partial penetration suffices under the Revised Penal Code, particularly when the victim is under the age of twelve or lacks consent due to intimidation. The victim's delayed reporting was understood in light of her age and the trauma endured. The Court highlighted that the allegations of denial and alibi presented by Mangubat were unconvincing when weighed against the positive identification and testimony of AAA.
Ruling on Legal Qualifications
The Supreme Court adjudged that while the minority of the victim had been established, the relationship between AAA and Mangubat was not. Consequently
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Case Overview
- This case involves an appeal by Rolando Mangubat, accused of simple rape on two counts against his granddaughter, referred to as AAA.
- The Court of Appeals (CA) decision dated January 23, 2006, affirms the Regional Trial Court's (RTC) findings of guilt on charges of qualified rape but modifies the penalty from death to reclusion perpetua.
- The case returns to the Supreme Court following Mangubat’s appeal against the CA's modified ruling.
Background of the Case
- Two separate Informations were filed against Mangubat on July 20, 1998, in the RTC of Pinamalayan, Oriental Mindoro, for the crimes of qualified rape.
- Criminal Case No. P-5788 pertains to an incident in 1997, while Criminal Case No. P-5789 relates to an incident on June 13, 1998.
- Both cases involve AAA, who was ten years old during the first incident and eleven years old during the second.
Allegations
- Criminal Case No. P-5788: In 1997, Mangubat allegedly raped AAA in their home while her grandmother was away.
- Criminal Case No. P-5789: On June 13, 1998, Mangubat allegedly forced AAA to engage in sexual acts after isolating her at home.
Evidence Presented
- The prosecution's case relied on the testimonies of AAA and Dra. Adelaida Malaluan, who examined AAA post-assault.
- AAA detailed her experiences in a consistent and emotional manner, describing both incidents of sexual abuse.
- The defense consisted of Mangubat’s