Case Summary (G.R. No. 130607)
Applicable Law
The relevant legal framework includes the 1987 Philippine Constitution, Republic Act No. 7659, and Article 335 of the Revised Penal Code, which defines and penalizes the crime of rape and specifies circumstances that aggravate its nature.
Factual Background
The information filed against Rustico Rivera stated that on May 16, 1995, he allegedly committed the crime of rape against his 10-year-old daughter, involving acts of force and intimidation. During the trial, Alphamia testified about her experience of being sexually molested by her father. She recounted the immediate events leading to the assault, describing unwanted touching and the removal of her garments. Additionally, her younger sister, Nina Joy, testified that she witnessed the abuse while pretending to sleep.
Testimonies and Medical Evidence
Medical evidence was provided by Dr. Fe Mesina, who examined Alphamia shortly after the incident, indicating recent trauma and physical signs consistent with sexual abuse. Dr. Mesina’s medical report highlighted lacerations on the hymen suggesting sexual penetration. The defense presented their own medico-legal expert, Dr. Dominick L. Aguda, who also found evidence compatible with sexual intercourse although it was labeled as old and healed injuries.
Defense's Argument
The defense contended that the accusations were fabricated, suggesting ill motives on the part of the victim’s mother and mother-in-law. Rustico claimed to have been elsewhere during the incident and argued that the charges arose from a conflict with his wife.
Trial Court's Decision
The trial court found Rustico guilty beyond reasonable doubt of incestuous rape and imposed the death penalty, considering the victim's age and her parental relationship with the offender as aggravating factors. The court underscored the victim's credible testimony and psychological impact on both her and her sister.
Affirmation of the Decision
In the automatic review by the Supreme Court, it was emphasized that the prosecution's evidence, particularly the coherent and candid testimonies of the victims, strongly substantiated the charges. The Court rejected the defense's claims of fabrication, stating it is implausible for young children to concoct such seri
...continue readingCase Syllabus (G.R. No. 130607)
Case Overview
- The case revolves around the automatic review of Rustico Rivera's conviction for the crime of qualified rape against his 10-year-old daughter, Alphamia A. Rivera.
- The primary legal issue is whether the constitutional presumption of innocence has been overcome by the prosecution to support the trial court's judgment of guilt beyond a reasonable doubt, resulting in the imposition of the death penalty.
Background Information
- The Information filed against Rustico Rivera in Criminal Case No. 778-M-95 accused him of committing rape on May 16, 1995, in Calumpit, Bulacan.
- The charge was based on the allegation that he forcibly had carnal knowledge of his minor daughter against her will.
The Prosecution's Case
Victim's Testimony:
- Alphamia, the victim, testified about the incident, detailing how her father touched her inappropriately and ultimately penetrated her.
- She described the events leading to the assault, including her father's threats that prevented her from reporting the abuse.
- Her younger sister, Nina Joy, corroborated Alphamia's account by testifying that she witnessed the act while pretending to be asleep.
Medical Evidence:
- Dr. Fe Mesina examined Alphamia the day after the incident, noting physical signs consistent with sexual assault.
- The medical report indicated old lacerations and tenderness in the genital area, supporting the claim of recent penetration.
Family Dynamics:
- Alphamia and her siblings lived with their parents in a small home, and t