Case Summary (G.R. No. 120625-29)
Applicable Law and Charges
The relevant law under which the accused was charged is Article 335 of the Revised Penal Code, as amended by Republic Act No. 7659, which defines and penalizes rape. Criminal Cases Nos. 1964-1969 involve allegations of sexual assault against his daughters, with specific charges detailing instances of rape occurring between August 24 and August 26, 1994.
Procedural History
On November 24, 1994, initial Informations were filed against Carlito Marahay, and on December 2, 1994, he was arraigned, pleading not guilty. Repeatedly throughout the proceedings, the relationship between the accused and the victims, as well as the victims’ ages (12 and 14), were stipulated during the pre-trial.
Prosecution's Theory
The prosecution presented a narrative where the accused, armed with threats and intimidation, sexually assaulted both daughters in their home and at a family farm. Testimonies from the victims were provided, detailing how they were assaulted by their father, including graphic accounts of the acts and the emotional anguish experienced during these incidents. Medical examinations corroborated the claims, indicating healed lacerations consistent with sexual intercourse.
Defense Arguments
The defense posited that the rape allegations were fabricated by the mother due to marital discord and the instability of their relationship. Furthermore, the accused claimed a moment of madness where he purportedly lost control, asserting that his daughters did not resist, thus disputing the charges based on the failure to demonstrate force or intimidation.
Trial Court's Judgment
On January 11, 1995, the Regional Trial Court rendered its decision, convicting the accused-appellant on all counts and imposing the death penalty, alongside moral and exemplary damages to the victims. The trial court relied heavily on the testimonies of the victims and the medical evidence presented.
Legal Principles on Rape
The court underscored several key legal principles guiding rape cases, including the inherent difficulty of proving such crimes, the necessity of scrutinizing the complainant's testimony with caution, and that the prosecution's evidence must stand on its own.
Appellate Review and Findings
The Supreme Court, upon reviewing the evidence, found discrepancies and inadequate proof concerning several charges. Specifically, it noted the prosecution's failure to prove beyond reasonable doubt the elements constituting rape in some counts, particularly those alleging incidents that occurred outside the verified accounts.
Decision on Sentences
The Supreme Court ultimately modified the trial court's de
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Case Background
- The case involves the automatic review of a Joint Decision rendered by the Regional Trial Court (RTC), Branch 19, Catarman, Northern Samar.
- Carlito Marahay y Moraca was convicted of five counts of rape against his daughters, AAA (12 years old) and BBB (14 years old), and was sentenced to death for each count.
- The trial court also ordered the accused to pay moral damages of P50,000.00 and exemplary damages of P30,000.00 to each victim.
Charges and Proceedings
- The initial charges were filed by Provincial Prosecutor Romeo M. Resuello on November 24, 1994, for two counts of rape.
- Subsequently, on November 29, 1994, Amalia P. Marahay, the mother of the victims, filed amended complaints, leading to three additional counts of rape.
- The accused-appellant pleaded not guilty during his arraignment on December 2, 1994, and a joint trial ensued thereafter.
Prosecution's Theory
- The prosecution's theory revolves around the rape of two underage daughters by their father, Carlito Marahay.
- It was established that the family lived in Barangay Bantayan, Municipality of San Roque, Northern Samar, and that the accused was their father.
Events of the Crime
- On August 24, 1994, both victims accompanied the accused to their farm to make copra.
- After supper, they went to sleep in a farmhouse where the accused sexually assaulted both daughters, beginning with BBB.
- BBB testified to being awoken by her father’s advances, which included pinching, kissing, and ultimately, sexual intercourse against her will.
- AAA was also assaulted in t