Case Summary (G.R. No. 112087)
Charges and Initial Proceedings
On February 10, 1992, Ma. Esther U. Toquilar executed a complaint against Alexander Soan accusing him of rape. Following a preliminary investigation which yielded probable cause, Soan was charged with rape in an Information dated March 9, 1992. The indictment states that on December 14, 1991, Soan, utilizing threats and intimidation, engaged in sexual intercourse with Ma. Esther against her will.
Trial and Testimonies
At his arraignment on June 8, 1992, Soan pleaded not guilty. The prosecution presented Ma. Esther as the sole eyewitness, supported by testimonies from her mother, Emily Urbe Toquilar, and their neighbor, Lita Balawang Cronico, as well as a medical examination conducted by Dr. Jose M. Lopez. The key events described by Ma. Esther included being lured into the Alcantara family's comfort room, where Soan threatened her, forcibly removed her clothing, and engaged in sexual intercourse.
Appellant’s Defense
Soan provided an alibi, claiming he was at work during the alleged dates. Witnesses for the defense included his brother-in-law and a co-worker, who corroborated his account of working from 9:00 a.m. to 7:00 p.m. He described his activities on the dates as consistent with a work schedule, asserting his innocent whereabouts and denying the allegations.
Ruling of the Trial Court
The trial court found Soan guilty beyond reasonable doubt and sentenced him to reclusion perpetua. He was also ordered to pay the victim ₱40,000 in civil indemnity. This decision was grounded predominantly on the credibility of the victim's testimony and the corroborating evidence provided during the trial.
Appellant’s Arguments on Appeal
On appeal, Soan contested the trial court's judgment based on various claims: the conduct of the complainant before, during, and after the alleged incident; the supposed inconsistencies in the testimonies of the prosecution; the lack of proof of penetration; and the alleged ulterior motives of prosecution witnesses. Specifically, he argued that Ma. Esther’s behavior was unnatural for a child if an assault had occurred, and he emphasized discrepancies in her testimonies.
Analysis of Arguments
The appellate court found these arguments to lack merit. It ruled that the reactions of child victims post-assault cannot be measured by the norms applicable to adults. The court reinforced the principle that different individuals react differently to trauma, and a child's silence or passive behavior can often be a product of fear and psychological impact.
Credibility of Witnesses
The appellate court affirmed the trial court's finding of credibility in the prosecution's witnesses. The discrepancies pointed out by the appellant were deemed immaterial and not sufficient to undermine the overall testimony which established the compelling case against him. The court noted that, per established law, even partial penetration
...continue reading
Case Syllabus (G.R. No. 112087)
Case Background
- The case involves Alexander Soan y Belarmino, who was charged and convicted of raping his daughter's ten-year-old playmate, Ma. Esther U. Toquilar.
- The complaint was filed on February 10, 1992, after the preliminary investigation indicated probable cause for the charges.
- The Information dated March 9, 1992, detailed that the crime occurred on December 14, 1991, in Binan, Laguna, where Soan allegedly used threats and intimidation against the minor.
Procedural History
- The case was docketed as Crim. Case No. 7319-B and assigned to the Regional Trial Court of San Pedro, Laguna, Branch 31.
- Soan was arraigned on June 8, 1992, and pleaded not guilty.
- The trial featured testimonies from the private complainant and three other witnesses: her mother (Emily Urbe Toquilar), Lita Balawang Cronico, and Dr. Jose M. Lopez.
Testimonies and Evidence
- Ma. Esther U. Toquilar described the events of December 14, 1991, detailing how she was lured by Soan into a comfort room where he assaulted her.
- She testified about the threats made by Soan, including threats to kill her and her family if she disclosed the incident.
- Lita Cronico witnessed the complainant exiting the comfort room shortly after Soan did and later reported her suspicions to Soan's wife.
- Upon learning from Lita about the incident in February 1992, Ma. Esther disclosed the details to her mother, leading to a medical examination.
Medical Examination
- Dr. Jose Lopez examined Ma. Esther and noted a "superficial healed