Case Summary (G.R. No. 185389)
Background of Charge
On June 20, 2001, Benjie Resurreccion was formally charged with Simple Rape under Article 266-A of the Revised Penal Code, as amended by Republic Act No. 8353. The incident occurred on December 5, 2000, where it was alleged that Benjie, acting as a domestic helper for AAA's family, forcibly had sexual intercourse with the 11-year-old girl, making the accusations serious given the victim's age.
Proceedings and Initial Verdict
Benjie was arraigned on October 2, 2001, where he pleaded not guilty. During pre-trial, the prosecution established the victim's age and recounted how the events unfolded on the day of the incident, including detailed testimony from AAA, her aunt BBB, and a medical professional. Following these proceedings, the RTC found Benjie guilty on August 30, 2005, sentencing him to reclusion perpetua and ordering him to pay P50,000 as damages.
Appeal to the Court of Appeals
Benjie appealed the RTC decision, arguing procedural irregularities and disputing the credibility of the victim’s testimony. The Court of Appeals, on March 24, 2008, affirmed the RTC's decision with modifications, specifically increasing the damages to P50,000 for civil indemnity and an additional P50,000 for moral damages.
Key Legal Issues
The case highlighted several legal principles regarding rape accusations, particularly the evidentiary requirements and the credibility of witnesses. It reiterated that the essence of statutory rape is simply the carnal knowledge of a woman under the age of twelve years, regardless of consent or force.
Assessment of Evidence
The RTC and the Court of Appeals based their decisions substantially on AAA's credible testimony. The victim convincingly recounted the events leading to her assault, describing Benjie’s threats and the ensuing violation. Despite the medical examination showing no lacerations or sperm presence in it, the absence of these findings was not sufficient to undermine the prosecution's case given AAA's clear narrative of the assault. Medical testimony established that such conditions could
...continue readingCase Syllabus (G.R. No. 185389)
Case Background
- The case concerns an appeal filed by Benjie Resurreccion against the Decision of the Court of Appeals dated 24 March 2008.
- The Court of Appeals affirmed with modifications the Decision of the Regional Trial Court (RTC) of Malaybalay, Bukidnon, Branch 8, which found Benjie guilty of Simple Rape.
- The charge was filed on 20 June 2001, under Article 266-A of the Revised Penal Code, as amended by Republic Act No. 8353.
Incident Details
- The incident occurred on 5 December 2000, in Barangay XXX, involving an 11-year-old victim identified as AAA.
- The Information stated that Benjie, who was a domestic helper in the victim's home, forcibly took AAA into a room, covered her mouth, undressed her, and had sexual intercourse with her against her will.
Arraignment and Pre-Trial
- Benjie was arraigned on 2 October 2001 and pleaded not guilty with the assistance of a counsel de oficio.
- The Pre-Trial Order dated 20 November 2001 included the admission that AAA was 12 years old at the time of the incident, based on her Certificate of Live Birth.
Prosecution's Evidence
- The prosecution presented testimonies from AAA, her aunt (BBB), and Dr. Marlyn Valdez-Agbayani, along with documentary evidence.
- Testimonies revealed that:
- AAA was born on 26 December 1988, making her 11 years old during the incident.
- Benjie grabbed AAA while she was going downstairs, covered her mouth, and forcibly dragged her to her room.
- Despite AAA’s attempts to struggle and escape, Benjie successfully penetrated her.
- After the act, Benjie threatened AAA not to disclose the incident.
Medical Examination
- The medical examination conducte