Case Summary (G.R. No. 218701)
Applicable Law
The case is adjudicated based on the provisions of the Revised Penal Code (RPC) regarding rape and attempted rape, as well as Republic Act No. 7610, which pertains to child abuse and exploitation.
Background of the Charges
The appellant faced three criminal charges: rape (Criminal Case No. 11767), violation of RA 7610 (Criminal Case No. 11768), and attempted rape (Criminal Case No. 11787). The rape charge alleged that in 1989, Ramirez caused his seven-year-old daughter to inhale a substance that rendered her unconscious, enabling him to have sexual intercourse with her. The second charge claimed that in 1996, he attempted to pull her onto a bed and threatened her life if she resisted. Lastly, the attempted rape charge involved a similar incident in 1996 where he was alleged to have commenced acts of sexual assault but did not complete them due to the victim's resistance.
Prosecution's Evidence
The prosecution's version presented the complainant's account, detailing the incidents and the subsequent actions taken by "AAA" to resist her father's advances. Several circumstantial evidences were offered: "AAA" was asleep at home, awakened by her father’s forceful actions, identified him as the perpetrator, and observed physical evidence such as blood and disarranged clothing upon regaining consciousness. A medical examination conducted by Dr. Annabelle Soliman corroborated that there could have been no injury despite intercourse.
Defense's Argument
The defense maintained a position of denial, arguing that the appellant was often away from home due to work obligations and disputing the allegations made against him. His account sought to cast doubt on the credibility of the complainant and questioned the timing and circumstances surrounding the accusations.
Ruling of the Regional Trial Court (RTC)
The RTC found the testimony of "AAA" credible and straightforward, rejecting the appellant's defense as mere denial without substantial evidentiary support. On April 30, 2012, the RTC convicted Gil Ramirez y Suyu on all counts, sentencing him to reclusion perpetua for rape, imposing penalties for violations of RA 7610, and sentencing for attempted rape.
Ruling of the Court of Appeals (CA)
On appeal, the CA modified the RTC decision. It found substantial circumstantial evidence supporting the guilt for rape while acquitting the appellant of violations against RA 7610 and attempted rape due to insufficient evidence. The CA emphasized the credibility of "AAA's" testimony and determined that her account, along with the surrounding circumstances, satisfied the threshold for a guilty verdict on the charge of rape.
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Case Overview
- This case involves an appeal from the decision of the Court of Appeals (CA) dated June 2, 2014, modifying the judgment of the Regional Trial Court (RTC), Branch 4 of Tuguegarao City, Cagayan.
- The appellant, Gil Ramirez y Suyu, was convicted of rape under Article 335 of the Revised Penal Code (RPC), violation of Section 5(b), Republic Act (RA) No. 7610, and attempted rape under par. 1 of Article 335 of the RPC.
- The case centers around the charges brought against Ramirez based on multiple incidents involving his daughter, referred to as "AAA."
Background of the Case
Criminal Case No. 11767 (Rape):
- Allegation: In 1989, Ramirez allegedly caused "AAA," then seven years old, to inhale a substance that made her lose consciousness, followed by sexual intercourse.
Criminal Case No. 11768 (Violation of RA 7610):
- Allegation: In 1996, Ramirez allegedly intimidated "AAA," then fourteen years old, and attempted to pull her to bed with threats of violence.
Criminal Case No. 11787 (Attempted Rape):
- Allegation: Also in 1996, Ramirez allegedly attempted to forcibly engage in sexual acts with "AAA," but she managed to escape.
Prosecution's Version
The prosecution presented "AAA" as the primary witness, detailing her traumatic experiences:
- In 1989, she lost consciousness after smelling a substance and later found blood on her shorts.
- In 1991, she was threa