Case Summary (G.R. No. 130334)
Factual Background
Merinor Bombales, aged 12 and later 13, alleged that Reynaldo PoAado, whom she considered a stepfather, sexually assaulted her on three occasions: October 8, 1995, September 8, 1996, and October 7, 1996. The accusations stemmed from incidents that happened while she and Reynaldo were alone at home. During these encounters, Reynaldo employed force and intimidation to perpetrate the assaults, covering Merinor’s mouth and tying her up to prevent her from escaping or calling for help.
Procedural History
Reynaldo PoAado was arraigned on January 29, 1997, pleading not guilty to all charges. Following a joint trial agreed upon by both parties, the trial court found him guilty beyond a reasonable doubt for all three counts. It sentenced him to death and ordered him to indemnify Merinor in the amount of P150,000, leading to an automatic review by the Supreme Court as per Republic Act No. 7659.
Trial Court's Findings
The trial court evaluated the credibility of Merinor’s testimony, which was characterized by detail and emotional sincerity. It noted that no woman would fabricate such serious allegations and endure the associated public scrutiny without a genuine motive to seek justice. The court also highlighted the absence of physical evidence, such as spermatozoa or external injuries, yet regarded Merinor's testimony as compelling and credible enough to warrant a conviction.
Appellant's Defense
Reynaldo PoAado denied the charges, claiming an alibi for the date of the first incident and stating that the family was together during the other alleged assaults. He attempted to shift the blame onto Merinor’s brother, Danilo, asserting that he was responsible for the allegations. Testimonies from family members supporting his claims were discredited by the straightforward and detailed account given by Merinor herself.
Supreme Court's Analysis
The Supreme Court upheld the trial court's findings regarding the credibility of Merinor's testimony but identified a significant legal deficiency in the prosecution's charging of Reynaldo as the stepfather in the information. This was pivotal as the law requires specific relation allegations to justify the imposition of the death penalty under qualifying circumstances per Republic Act No. 7659.
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Case Overview
- This case involves Reynaldo PoAado, who was charged with three counts of rape under Article 335 of the Revised Penal Code, as amended by Republic Act No. 7659.
- The incidents occurred on October 8, 1995, September 8, 1996, and October 7, 1996, against his stepdaughter, Merinor Bombales.
- The trial court found PoAado guilty beyond reasonable doubt, imposing the death penalty for each count.
Charges and Background
- The information for the charges specified that PoAado committed rape with grave abuse of parental authority on his stepdaughter, who was 12 and 13 years old at the time of the incidents.
- At the arraignment on January 29, 1997, PoAado pleaded not guilty, leading to a joint trial.
- The familial background was outlined, highlighting that Merinor viewed PoAado as a father figure after the separation of her biological parents.
Victim's Testimony
- Merinor testified about the sexual assaults, detailing the circumstances and methods used by PoAado to carry out the acts.
- On each occasion, she was alone in the house, studying, when PoAado would enter, undress her, and engage in sexual intercourse while covering her mouth to prevent her from shouting.
- The testimony included graphic details about the assaults and her feelings of helplessness during the incidents.
Medical Examination
- A medico-legal examination conducted by Dr. Lea Remonte on October 8, 1996, revealed significant findings:
- Normal external genitalia but an intact hymen with superficial laceration