Case Summary (G.R. No. 173052)
Charges and Allegations
Rogelio Pelagio was charged with three counts of rape under separate Informations, defined and penalized under Article 335 of the Revised Penal Code, as amended by RA 7659. The charges outlined that on three different occasions—August 22, 1997; August 30, 1997; and October 18, 1997—Rogelio allegedly assaulted his 15-year-old daughter, AAA, through means of force and intimidation.
Judgment of the Regional Trial Court
The Regional Trial Court (RTC) of Naga City found Rogelio guilty beyond reasonable doubt of all three counts of rape in a judgment dated February 19, 1999. The court sentenced him to death for each offense and ordered him to pay moral damages to AAA as well as exemplary and consequential damages, totaling P525,000. The RTC emphasized the heinous nature of the crimes, particularly given the familial relationship between the accused and the victim.
Appeal and Court of Appeals Decision
Following the death penalty sentence, the case was subject to automatic review and was subsequently transferred to the Court of Appeals (CA). On March 31, 2006, the CA upheld the RTC's conviction but modified the awards for civil indemnity, moral damages, and exemplary damages. The CA affirmed the decision to impose the death penalty while revising certain monetary damages payable to the victim.
Appellant's Arguments
Rogelio's appeal raised several assignments of error, primarily questioning the credibility of AAA's testimony and the motivations behind her allegations. He argued that the trial court erred in accepting AAA’s accusations without considering potential biases, including the alleged ill-will from his estranged wife. Furthermore, he posited that the physical evidence did not sufficiently support the allegations against him.
Credibility of the Victim's Testimony
Both the RTC and CA found AAA's testimony to be credible, highlighting the lack of motive to falsely accuse her father, as well as the psychological implications and trauma associated with incestuous rape. The courts adhered to legal principles emphasizing that the testimony of a rape victim, especially one of AAA's age, should be scrutinized closely yet given significant credence if consistent and straightforward.
Examination of Evidence
The courts noted that in rape cases, the absence of physical evidence such as lacerations or spermatozoa does not undermine the validity of the victim's accusations. The prosecution established the elements of rape through AAA's unequivocal testimony about the incidents, which was corroborated by the surrounding circumstances leading up to the report of the alleged offenses.
Sentencing Changes Post-RA 9346
With the enactment of Republic Act No. 9346, which
...continue readingCase Syllabus (G.R. No. 173052)
Case Overview
- Rogelio Pelagio y Bermudo (appellant) was charged with three counts of Rape by his daughter, AAA, under separate Informations.
- Each charge stemmed from incidents occurring on August 22, August 30, and October 18 in 1997.
- The accusations involved allegations of lewd designs, force, and intimidation by the accused against his minor daughter, who was 15 years old at the time.
Details of the Informations
Crim. Case No. 98-7037:
- Date: August 30, 1997
- Location: Barangay XXX, Philippines
- Incident occurred around 10:00 PM.
- AAA was allegedly raped against her will.
Crim. Case No. 98-7038:
- Date: August 22, 1997
- Location: Barangay XXX, Philippines
- Incident occurred around 9:30 PM.
- Similar allegations of rape against AAA.
Crim. Case No. 98-7142:
- Date: October 18, 1997
- Location: Barangay XXX, Philippines
- Incident occurred at 9:00 PM.
- The complaint included a medical certificate supporting the claims.
Trial and Judgments
- The appellant was arraigned and pleaded "not guilty" to all charges.
- On February 19, 1999, the Regional Trial Court (RTC) found the appellant guilty of Rape for all three counts and sentenced him to death for each offense.
- The court also ordered the appellant to pay AAA moral damages, exemplary damages, and consequential damages due to the trauma caused.
Automatic Review and Court of Appeals Decision
- The case was automatically elevated to the Supreme Court due to the imposition of the death penalty.