Case Summary (G.R. No. 173976)
Charges and Allegations
The appellant faced two counts of rape:
- Criminal Case No. C-70217 (Rape through Sexual Assault): This involved the unlawful and felonious sexual abuse of AAA, aged 12, on February 22, 2004.
- Criminal Case No. C-70859 (Qualified Rape): This charge specified that on February 9, 2004, the appellant forcibly had sexual intercourse with AAA against her will.
Proceedings and Evidence During Trial
After being arraigned and pleading not guilty, a joint trial commenced. The prosecution presented testimonies from AAA, her mother BBB, and medical experts regarding the physical examination of AAA, which confirmed signs of sexual abuse. Specifically, Dr. Mamerto Bernabe Jr.'s examination indicated that AAA was in a non-virgin state and had injuries consistent with sexual assault.
Victim’s Testimony and Corroboration
AAA testified about two separate incidents of sexual abuse by her father, detailing how he utilized threats and physical overpowering to prevent her from resisting. The testimony was corroborated by medical findings of lacerations and a subsequent pregnancy, which further supported the claims of forced sexual activity.
Appellant’s Defense
The appellant denied the charges, claiming he was not present at the crime scenes during the relevant dates. He alleged that the accusations were fabricated by BBB to coerce AAA into testifying against him.
Trial Court’s Findings
On May 15, 2012, the Regional Trial Court found the appellant guilty beyond reasonable doubt on both counts of rape. In Criminal Case No. C-70217, the appellant was sentenced to an indeterminate penalty of eight years of Prision Mayor to eighteen years of Reclusion Temporal, alongside monetary compensation to the victim. In Criminal Case No. C-70859, he received a sentence of Reclusion Perpetua.
Court of Appeals Decision
The Court of Appeals affirmed the trial court's decision but modified certain aspects, particularly the penalties and damages awarded to AAA. The appellate court decreased the indeterminate penalty's maximum term in the first case and stipulated specific amounts for civil indemnity, moral damages, and exemplary damages to be paid to the victim.
Legal Principles and Findings
The court relied on provisions of the Revised Penal Code regarding rape, specifically Article 266-A, which outlines the definitions and penalties associated with the crime. The elements needed for proving rape were carefully discussed, particularly with respect to the minor victim’s age and the relationship with the offender, which constituted aggravating circumstance
...continue readingCase Syllabus (G.R. No. 173976)
Case Overview
- The case involves the appeal of Eduardo Marmol y Bauso, Jr. against the decision of the Court of Appeals affirming his conviction for two counts of rape against his minor daughter, referred to as AAA.
- The relevant decisions stem from the Regional Trial Court (RTC) of Caloocan City, with the case numbers C-70217 and C-70859.
Charges and Allegations
Criminal Case No. C-70217:
- Date of offense: February 22, 2004.
- Accused allegedly sexually abused AAA, then 12 years old, by inserting his finger into her genital organ against her will.
Criminal Case No. C-70859:
- Date of offense: February 9, 2004.
- Accused allegedly had sexual intercourse with AAA through force and intimidation.
Trial Proceedings
- Upon arraignment, the accused pleaded not guilty, leading to a joint trial.
- The prosecution presented witnesses including AAA, her mother BBB, and medical professionals.
- Evidence included AAA's birth certificate confirming her age and details of the alleged incidents.
Victim's Testimony
- On February 9, 2004, AAA was alone at home when the accused forced her onto the bed and had sexual intercourse with her.
- On February 22, 2004, while sleeping with her family, AAA was awoken by the accused who engaged in sexual assault.
- AA