Case Summary (G.R. No. 172372)
Procedural History
The appellant was charged under three separate Informations with statutory rape. The RTC issued its decision on February 19, 2001, in which it found Teodoro guilty beyond a reasonable doubt for two counts of statutory rape, sentencing him to reclusion perpetua for each count, while acquitting him of a third charge. The CA later affirmed this decision on January 19, 2006.
Charges and Testimonies
The charges were categorized as follows:
- Criminal Case No. 8538: Allegations of rape on June 18, 1995.
- Criminal Case No. 8539: Allegations of rape in early July 1995.
- Criminal Case No. 8540: Allegations of rape on March 30, 1996, for which he was acquitted.
AAA's testimonies were pivotal in the prosecution's case. During the trials, she detailed her experiences of sexual assault, emphasizing her age and the force and intimidation used by the appellant. Medical examinations corroborated her testimony, presenting findings such as healed lacerations consistent with sexual intercourse and the presence of sperm cells.
Legal Definition and Implications of Statutory Rape
The law penalizes statutory rape under Article 335 of the Revised Penal Code, which specifically includes the provision that carnal knowledge of a woman under twelve years of age constitutes rape, irrespective of the presence of force or intimidation. The law liberates the minor from the requirement of showing resistance or lack of consent because of their presumed incapacity to understand the nature of the act.
Evaluation of Evidence
The Court found AAA's testimonies credible and directly linked the appellant to the crimes. The sustained consistency of her recollection, along with the medical findings, established both the occurrence of the crimes and the age of the victim at the time, confirming the statutory nature of the offenses. As stated, the essential inquiry was solely whether carnal knowledge took place and whether AAA was below twelve years of age.
Appellant's Defense and its Rejection
The appellant's defense primarily rested on denial, claiming the acts were consensual, and argued procedural flaws regarding the vagueness of the Informations. However, the Court upheld that the date of the alleged crime did not need to be precisely stated, only the approximate time was sufficient under Rule 110 of the 2000 Revised Rules on Criminal Procedure. The appellant's general claims of innocence and inconsistencies were insufficient to negate AAA's detailed account that was supported by medical evidence.
Final Ruling and Modifications
The Court denied the appellant's appeal due to its lack of merit while modifying the indemnity awards. It mandated the affirmation of the RTC's imposition of reclusion perpetua for two counts of statutory rape. The Court also rec
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Case Reference
- G.R. No. 172372
- Date of Decision: December 04, 2009
- Division: Second Division
- Judgment: Affirmation of the Regional Trial Court (RTC) decision by the Court of Appeals (CA)
Background of the Case
- The appellant, Romar Teodoro y Vallejo, was charged with statutory rape under three separate Informations.
- The specific charges were as follows:
- Criminal Case No. 8538: Rape committed on June 18, 1995.
- Criminal Case No. 8539: Rape committed in the first week of July 1995.
- Criminal Case No. 8540: Rape committed on March 30, 1996 (appellant acquitted).
- The RTC found the appellant guilty of two counts of statutory rape, imposing the penalty of reclusion perpetua for each count.
Antecedent Facts
- The prosecution's evidence included testimonies from three key witnesses:
- Dr. Rosalina Caraan-Mendoza: Conducted a medical examination of the victim (AAA) and found physical evidence consistent with sexual assault.
- Donna Catapang: Conducted laboratory tests confirming the presence of sperm cells in AAA's vaginal smear.
- AAA (the victim): Provided detailed accounts of the rapes, identifying the appellant as the perpetrator.
Testimonies and Evidence
Victim's Testimony:
- AAA was born on July 21, 1983, and had known the appellant since 1993.
- Described the assaults in detail, noting threats made by the appellant to deter her from reporting.
- Consistent in her identification of the appellant during all insta