Case Summary (G.R. No. 183531)
Key Dates
- Incident Date: July 8, 1998
- Information Filed: January 8, 1999
- RTC Decision: November 26, 2009
- Court of Appeals Decision: April 28, 2011
- Supreme Court Decision: June 5, 2013
Applicable Law
The relevant laws in this case include Articles 266-A and 266-B of the Revised Penal Code of the Philippines, as amended by Republic Act No. 7659 and 8353. Under these provisions, acts constituting statutory rape are defined, including circumstances concerning the age of the victim and the penalties associated with such offenses.
Factual Background
The prosecution's account stated that on July 8, 1998, AAA was playing with friends when she was invited by her neighbor, CCC, to Piosang's house under the latter's instructions. Soon after entering, Piosang allegedly assaulted AAA in a detached comfort room, threatening both children with a knife. He forcibly committed acts of sexual abuse on AAA while ordering CCC to also engage in sexual acts. After the assault, both children were threatened against disclosing the incident.
Months later, AAA revealed the assault to her mother after being instructed about inappropriate touch. A medical examination confirmed signs of sexual abuse.
Court Findings
The RTC found Piosang guilty of rape beyond a reasonable doubt, sentencing him to reclusion perpetua and ordering him to pay civil, moral, and exemplary damages to AAA. The Court of Appeals affirmed this decision with modification to the damages awarded.
Defense Argument
Piosang denied the allegations, claiming that he was at home during the incident, relying on an alibi. He asserted that CCC was the actual perpetrator and indicated that DDD, CCC's mother, attacked CCC after he confessed to AAA's rape. Additionally, Piosang suggested that the prosecution's case was undermined by his suggestion to have AAA medically examined and claims of a purported extortion attempt by an attorney connected to the case.
Supreme Court Decision
The Supreme Court upheld the decisions of the lower courts, emphasizing the credibility of AAA's testimony despite her young age. The testimony delivered was deemed straightforward, consistent, and corroborated by the additional testimony of CCC and the medical findings indicating ab
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Case Overview
- The case involves an appeal by Ricardo Piosang against the Decision dated April 28, 2011, from the Court of Appeals (CA-G.R. CR.-H.C. No. 04303).
- The core issue is the conviction of Piosang for the crime of statutory rape against a minor, AAA, who was only four years old at the time of the offense.
- The Regional Trial Court (RTC) of Quezon City had found Piosang guilty beyond reasonable doubt and imposed a sentence of reclusion perpetua, along with civil, moral, and exemplary damages to the victim.
Incident Details
- The alleged crime occurred on July 8, 1998, in Quezon City.
- According to the Information filed by the City Prosecutor, Piosang committed rape by forcibly inserting his penis into AAA’s vagina.
- The victim was accompanied by a boy, CCC, who witnessed the crime and was threatened by Piosang during the incident.
Prosecution's Evidence
- AAA testified about being invited by CCC to Piosang's house, where they were subsequently pushed into a comfort room.
- During the incident, Piosang brandished a knife, threatened both children, and assaulted AAA while CCC was coerced into holding her.
- Medical examination of AAA revealed healed lacerations, indicating sexual abuse.
Defense's Evidence
- Piosang denied the charges, claiming he was at home during the incident and suggested that CCC was the actual perpetrator.
- He contended that CCC’s initial reluctance to disclose the incident indicated his own innoc