Case Summary (G.R. No. 179187)

Conviction and Charges

The Court of Appeals affirmed the conviction of Renato Talusan y Panganiban for kidnapping with rape of a six-year-old minor, AAA. The Information filed against him detailed that from January 15 to January 23, 2004, he unlawfully kidnapped AAA, detaining her against her will for eight days. During this period, he subjected her to sexual abuse by inserting his finger into her vagina multiple times, which was detrimental to her physical and psychological development.

• Conviction affirmed by the Court of Appeals.
• Charges included kidnapping and rape of a minor.
• Detention lasted eight days.
• Sexual abuse involved multiple instances of penetration.

Evidence and Testimony

The prosecution's evidence revealed that on January 14, 2004, appellant lured AAA under the pretense of going to Jollibee. Instead, he took her to a house in Imus, Cavite, where he introduced her as his daughter. AAA was under his control for eight days, during which he abused her daily. After AAA failed to return home, her stepfather reported her missing, leading to the eventual apprehension of the appellant.

• Appellant lured AAA with false promises.
• AAA was held in a different location for eight days.
• Her stepfather reported her missing after she did not return home.
• Appellant was apprehended on January 23, 2004.

Medical Examination and Findings

A medico-legal examination conducted by Dr. Pierre Paul Carpio revealed that AAA had deep fresh lacerations in her hymen, indicating recent sexual activity. The examination concluded that the findings were compatible with a recent loss of virginity, which supported the charges of rape.

• Medical examination confirmed sexual abuse.
• Findings included deep lacerations in the hymen.
• Conclusions indicated recent loss of virginity.

Trial Court Proceedings

During the arraignment, the appellant pleaded guilty with the assistance of counsel. The trial court conducted a thorough inquiry into the voluntariness of his plea, confirming that he understood the implications of his admission. Despite his guilty plea, the court required the prosecution to present evidence, which ultimately led to his conviction.

• Appellant pleaded guilty during arraignment.
• Trial court conducted a thorough inquiry into the plea's voluntariness.
• Prosecution was required to present evidence despite the guilty plea.

Sentencing and Modifications

The trial court sentenced the appellant to death, citing the gravity of the crime and the established qualifying circumstance of the victim's minority. However, due to the enactment of Republic Act No. 9346, which prohibits the death penalty, the Court of Appeals modified the sentence to reclusion perpetua without eligibility for parole.

• Initial sentence was death penalty.
• Sentence modified to reclusion perpetua due to new legislation.
• Victim's minority was a qualifying circumstance.

Civil Indemnity and Moral Damages

The appellate court also addressed the awards for civil indemnity and moral damages. It upheld the trial court's decision to grant P50,000 for each but increased these amounts to P75,000 each, in line with p...continue reading