Case Summary (G.R. No. 189821)
Factual Background
On October 10, 2000, the appellant was formally charged in the RTC with multiple counts of rape stemming from incidents that occurred on June 24, 2000. The victim, AAA, provided testimony detailing the abuse, stating that on June 14, 2000, the appellant forcibly engaged in sexual acts with her in a cornfield. Following this incident, AAA claimed to have been raped multiple times afterward. Medical examinations indicated that AAA suffered physical injuries consistent with the allegations, including signs of infection and abrasions.
RTC Ruling
In a decision dated November 29, 2005, the RTC convicted the appellant of qualified rape based on AAA’s credible testimony. The appellate court dismissed the appellant's claims regarding the lack of medical evidence for penetration and sentenced him to death, along with financial compensation orders amounting to P100,000.00 for civil indemnity.
CA Ruling
Upon appeal, the Court of Appeals (CA) reviewed the RTC’s decision and upheld the victim's testimony while downgrading the charge from qualified rape to simple rape. The CA concluded that while the evidence was substantial, the prosecution failed to substantiate the victim's age definitively at the time of the crime. Consequently, the CA sentenced the appellant to reclusion perpetua and articulated a breakdown of damages to include P50,000.00 for civil indemnity, P50,000.00 for moral damages, and P25,000.00 for exemplary damages.
Our Ruling
The Supreme Court affirmed the decisions of the lower courts, emphasizing that a victim's credible testimony is sufficient for conviction in sexual assault cases, irrespective of medical corroboration. It highlighted that the prosecution must provide evidence of penetration, albeit slight, and that the absence of consistent medical documentation does not undermine the victim's account. The Court concurr
...continue readingCase Syllabus (G.R. No. 189821)
Case Background
- The case involves the appeal of Antonio Otos (alias Antonio Omos) against the decision of the Court of Appeals (CA) dated February 25, 2009.
- The appeal stems from a conviction for multiple rape committed against his five-year-old stepdaughter, referred to as AAA.
- The original charge was filed in the Regional Trial Court (RTC), Branch 2, Tagum City, Davao del Norte.
Factual Antecedents
- On October 10, 2000, the appellant was charged with multiple counts of rape against AAA, allegedly committed on June 24, 2000.
- During the trial, AAA provided detailed testimony regarding the incidents.
- The evidence indicated that on the evening of June 14, 2000, the appellant took AAA to their cornfield, where he sexually assaulted her, causing her extreme pain.
- Following the assault, the appellant threatened AAA to remain silent about the incident.
- After experiencing physical discomfort, AAA disclosed the assaults to her mother, BBB, leading to their departure from the appellant's residence.
- Medical examinations confirmed AAA's injuries, which included an inflamed labia minora with multiple abrasions and a urinary tract infection.
- The appellant denied the allegations, claiming they were fabricated by BBB out of anger.