Case Summary (G.R. No. 82303)
Allegations and Initial Proceedings
Rodrigo Pascua was accused of raping Magdalena Cambaleza, who was under twelve years of age at the time of the alleged crime in November 1982. The prosecution alleged that Pascua, armed with a bayonet, forcibly had carnal knowledge of the victim. Magdalena’s narrative included a second incident of sexual assault on March 30, 1984, which added complexity to the case but was not charged in the indictment. Pascua pleaded not guilty during the arraignment on February 20, 1987, and was later found guilty by the trial court, receiving a sentence of reclusion perpetua and a fine of P25,000 for damages to the victim.
Details of the Prosecution's Case
The prosecution's case rested on the testimony of the complainant, Magdalena, who described two incidents of rape: the first in November 1982 by the riverbank in Gabaldon and the second two years later in Nueva Vizcaya. Following her reports to her mother and the medical examination, which confirmed old healed lacerations, the case was pursued in court. The medical certificate indicated that she had lost her virginity, supporting the assertion that sexual activity occurred.
Defense and Testimony of the Accused
Rodrigo Pascua's defense focused on denying the allegations, attributing them to familial strife and personal animosities, particularly revolving around his relationship with Agnes. He presented a narrative whereby Agnes became involved with a barangay captain, which he claimed fueled animosity against him, potentially motivating false accusations from Magdalena. He further disputed the credibility of the allegations, noting delays in reporting the incidents and inconsistencies in the testimonies presented.
Credibility Issues and Inconsistencies
A critical aspect of the court's evaluation involved assessing the credibility of Magdalena and her mother's accounts. Several inconsistencies emerged, such as contradictions regarding the timeline of events, the interactions with the accused post-alleged incidents, and the nature of their living arrangements. Notably, Agnes's continued residence with Pascua after the alleged assaults raised questions about the urgency of the accusations.
Medical Evidence and Its Implications
The medical examination revealed that Magdalena was still a virgin at the time of the examination in 1984, despite her claims of previous assaults. This evidence cast doubt on the prosecution's narrative, particularly reg
...continue readingCase Syllabus (G.R. No. 82303)
Case Overview
- This case revolves around the conviction of Rodrigo Pascua for the crime of rape.
- The case was decided by the Second Division of the Supreme Court of the Philippines on December 21, 1989, under G.R. No. 82303.
- The complainant is Magdalena Cambaleza, who was allegedly raped by her stepfather, Rodrigo Pascua.
Background of the Case
- The sworn complaint by the alleged victim, Magdalena Cambaleza, was dated April 23, 1984.
- Assistant Provincial Fiscal Marcelina Tangunan-Annang filed the information against Pascua on October 8, 1986, in the Regional Trial Court, Cabanatuan City.
- The allegation detailed an incident in November 1982, where Pascua allegedly used a bayonet to force himself on the then 11-year-old Magdalena.
Proceedings in Lower Courts
- Upon arraignment on February 20, 1987, Pascua entered a plea of "not guilty."
- The trial court found him guilty beyond reasonable doubt and sentenced him to suffer reclusion perpetua and ordered him to indemnify the complainant P25,000.00.
Evidence Presented by the Prosecution
- Magdalena Cambaleza, born December 17, 1970, was one of the four children of Agnes Suara and the late Domingo Cambaleza.
- Pascua was the common-law husband of Agnes and lived with her and their children in Sitio Dalag, Gabaldon, Nueva Ecija.
- The prosecution's case hinged on the testimony of Magdalena, who rec