Case Summary (G.R. No. 208091)
Charges and Allegations
Benito Molejon was charged with five counts of Qualified Rape and eleven counts of Acts of Lasciviousness. The qualified rape accusations involve three instances against his 13-year-old stepdaughter AAA and two against his 11-year-old stepdaughter BBB. The allegations state that rape was committed through force, threat, and intimidation, with the aggravating circumstances that the victims were minors and the offender was their stepparent.
Testimonies and Evidence
During trial, the prosecution presented key witnesses, including the victims AAA and BBB, their mother CCC, a doctor, and a police officer. Both AAA and BBB provided detailed testimonies describing the sexual abuse they underwent at the hands of Molejon. They recounted instances of molestation, with graphic descriptions of the acts committed against them. Importantly, their mother discovered the abuse happening in real-time, prompting the victims to disclose the entire ordeal to her.
Defense Strategy
Molejon denied the accusations, asserting that no threats were made against the victims and questioning their credibility. He argued that any interaction with the victims was consensual and characterized their seemingly normal behavior post-incident as contrary to the actions of a victim. His defense relied on alibi and denial, which the courts generally regard as weak when confronted with credible testimonies from victims.
Lower Court Rulings
The Regional Trial Court (RTC) convicted Molejon of the charges on August 5, 2010, determining that the testimonies presented were credible and consistent, pointing to his guilt beyond a reasonable doubt. The RTC found the defense's claims of inconsistency in the victims' testimonies unpersuasive, emphasizing that minor discrepancies do not undermine credibility, especially considering the context of the traumatic experiences recounted.
Court of Appeals Decision
The Court of Appeals (CA) affirmed the RTC's ruling with modifications regarding the damages awarded to the victims. It highlighted that both AAA and BBB’s testimonies were direct and detailed, reiterating the influence of psychological and moral intimidation that inhibited their capability to resist effectively.
Supreme Court Findings
The Supreme Court upheld the decisions of the lower courts, confirming the convictions. The Court emphasized the trial court's capacity to assess the witnesses and the accountability of Molejon's actions under the law. It reiterated that intimidation, whether through physical or moral coercion, qualifies as sufficient grounds for a conviction of rape. The Court also clarified that the victims’ lack of stronger resistance did not imply consent or diminutive culpability from the offender.
Sentencing and Damages
Molejon was sentenced to suffer the penalty of reclusion perpetua without eligibility for parole for each count
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Case Background
- The appeal challenges the Decision dated April 24, 2013, of the Court of Appeals (CA) in CA-G.R. CR. HC No. 00919-MIN, which modified the Joint Decision dated August 5, 2010, of the Regional Trial Court (RTC), Branch 1 of Isabela, Basilan.
- Accused-appellant Benito Molejon was convicted of five counts of Qualified Rape, under Article 266-A of the Revised Penal Code (RPC), as amended by Republic Act No. 8353, and eleven counts of Acts of Lasciviousness under Article 336 of the RPC.
- The charges involved three counts of rape against his 13-year-old stepdaughter AAA and two counts against his 11-year-old stepdaughter BBB.
Charges and Allegations
Qualified Rape Charges:
- Five separate informations were filed for Qualified Rape against AAA and BBB.
- The allegations described the commission of the crimes involving force, threat, and intimidation, highlighting the victims' ages and their relationship to the accused as his stepdaughters.
Acts of Lasciviousness Charges:
- Eleven separate informations detailed acts of lasciviousness committed against the two stepdaughters.
- The accusations included specific actions like touching and fingering the victims' genitalia, with force used to accomplish these acts.
Trial and Testimonies
During the trial, the prosecution presented five witnesses: the victims AAA and BBB, their mother CCC, and medical and police personnel.
AAA's Testimony:
- Described repeated incidents of rape and sexual abuse by her stepfather from 2001 to January 2003.
- Recounted graphic details of the assaults and the physical pain endured during the acts.
BBB's T