Case Summary (G.R. No. 205308)
Nature of the Case
Oscar Santos y Encinas was accused in 16 information charges: one for rape in relation to Republic Act No. 7610 (RA 7610) and 15 for acts of lasciviousness under Article 336 of the Revised Penal Code (RPC). The incidents date from June 1997 to September 1998.
Allegations
The rape charge alleges that in June 1997, Santos used force and intimidation to have carnal knowledge with AAA. The acts of lasciviousness charges involved incidents where Santos kissed AAA and licked her vagina on various occasions. All acts were stated to be motivated by lust and were against AAA's will.
Testimonies
Testimony from AAA detailed how she was forcibly taken by Santos and subjected to sexual abuse, including acts of molestation and the threat of silence through fear. AAA indicated that this abuse was ongoing during the specified time.
Defense and Counterarguments
Santos denied the allegations, presenting an alibi that he was mostly at sea for work as a fisherman during the times of the incidents. His defense was deemed weak as it lacked corroboration and did not disprove the possibility of his presence at the crime scene.
Decision of the Trial Court
On October 21, 2010, the trial court found Santos guilty beyond reasonable doubt of the crimes charged, imposing a sentence of reclusion perpetua for the rape charge and various terms of imprisonment for the acts of lasciviousness. The court also ordered the payment of civil and moral damages to the victim.
Appellate Court Ruling
The Court of Appeals, on April 20, 2012, affirmed the trial court's decision with certain modifications in the penalties for the damages awarded. The appellate court found Santos's defense insufficient compared to AAA’s credible testimony.
Affirmation of Credibility
Both the trial and appellate courts emphasized the consistency and detailed account of AAA's testimony, which remained unshaken even during cross-examination. The courts provided that such credible witness testimony outweighs alibi and denial defenses.
Legal Implications
The case underscores the definitions of rape and acts of lasciviousness under Philippine law, particularly addressing the child’s age, and highlights the importance of victim testimony in sexual abuse cases. Furthermore, it examines how certain acts might constitute rape under amended provisions even though they were charged differently due to timing.
Final Sentencing Modifications
The Supreme Court's ruling confirmed the conviction of Santos. Modifi
...continue readingCase Syllabus (G.R. No. 205308)
Case Background
- This case is an appeal from the decision of the Court of Appeals dated April 20, 2012, in CA-G.R. CR-HC No. 04793.
- The appeal concerns Oscar Santos y Encinas, who was found guilty beyond reasonable doubt of rape and 15 counts of violation of Article 336 of the Revised Penal Code (RPC) in relation to Section 5 of Republic Act No. 7610.
- The appellant was charged with 16 informations: one count of rape and 15 counts of acts of lasciviousness involving his seven-year-old goddaughter, identified as AAA.
Charges and Allegations
- Rape Charge (Crim. Case No. 7587): Alleged to have occurred in June 1997, where the appellant forcibly had carnal knowledge of AAA against her will.
- Acts of Lasciviousness (15 counts, Crim. Cases Nos. 7588-7602): Allegations included kissing AAA's neck and lips, as well as licking her sex organ on various occasions from July 1997 to September 1998.
- The informations outlined the use of force and intimidation motivated by lust and lewd design.
Testimonies and Evidence
AAA's Testimony:
- Described incidents starting in June 1997, involving being grabbed by the appellant, taken to his house, and subjected to sexual acts.
- Reported that on multiple occasions, appellant would give her small amounts of money after the incidents.
- AAA's account included detailed descriptions of the acts, indicating a pattern of abuse over time.
Mother's Testimony:
- Learned of the abuse through another relative and confirmed AAA's experiences only after inquiry.