Case Summary (G.R. No. 225511)
Charge and Proceedings
The Regional Trial Court (RTC) found the appellant guilty beyond a reasonable doubt of rape under Article 266-A of the Revised Penal Code (RPC) and of violating Section 5(b) of Republic Act No. 7610 in separate Informations. The appellant pleaded not guilty, leading to a trial where evidence was presented by both the prosecution and the defense.
Prosecution’s Evidence
The prosecution's case detailed two distinct incidents of sexual abuse committed by the appellant against AAA. The first incident occurred in May 2009, when the appellant allegedly threatened AAA while her mother was away. The second incident occurred in June 2009, also during a time when AAA's mother was occupied. AAA later became pregnant, and a medical examination confirmed this. Testimony from a psychologist indicated that AAA had significant intellectual impairments, which the prosecution argued exempted her from being capable of giving legal consent.
Defense Strategy
The defense acknowledged the appellant's relationship with AAA’s mother but denied the allegations of rape. The appellant claimed there was no evidence of force or intimidation and argued for a shift in his defense to claim consent. Notably, he referred to a statement from AAA during cross-examination where she purportedly agreed to the sexual acts.
RTC Ruling
The RTC found AAA’s testimony credible, ruling against the appellant's claims of consent and alibi. The court declared that the presence of force, threat, and minority of the victim constituted the elements of rape under the RPC. The court sentenced the appellant to reclusion perpetua for rape and prescribed monetary damages to AAA.
Court of Appeals Decision
Upon appeal, the Court of Appeals affirmed the RTC's decision, modifying some aspects such as the monetary awards. The appellate court maintained that consent could not legally be granted by a minor and that the prosecution had adequately proved the elements of both crimes.
Supreme Court's Findings
The Supreme Court partially granted the appeal. It affirmed the conviction for qualified rape in Criminal Case No. 6072, noting the element of the victim's minority and the appellant's familial relationship to her as aggravating factors. The Court emphasized the victim's inability to give consent due to her mental impairment, thus supporting the qualified rape charge.
Analysis of RA 7610 Charges
However, the Court found that the Information in Criminal Case No. 6073
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Case Background
- Vicente Vaas y Balderama (appellant) appeals the January 29, 2015 Decision of the Court of Appeals (CA) in CA-G.R. CR-HC No. 06215.
- The CA's decision affirmed with modification the June 7, 2013 Judgment of the Regional Trial Court (RTC) of Ligao City, Albay.
- The RTC found the appellant guilty beyond reasonable doubt of rape under Article 266-A of the Revised Penal Code (RPC) in Criminal Case No. 6072 and violation of Section 5(b) of Republic Act No. 7610 in Criminal Case No. 6073.
- The victim, referred to as "AAA," was a 16-year-old minor at the time of the offenses.
Charges and Allegations
Criminal Case No. 6072 (Rape):
- Appellant was charged with raping AAA on or about May 2009 at approximately 3:00 a.m.
- The crime was committed with lewd design, through force, threat, and intimidation, resulting in AAA's pregnancy.
- Aggravating circumstances included the victim's minority and appellant's relationship to her as the live-in partner of her mother.
Criminal Case No. 6073 (Violation of RA 7610):
- The charge alleged that on June 15, 2009, at around 6:00 a.m., appellant committed sexual intercourse with AAA while she was a minor.
- The act was described as debasing and demeaning to the child's dignity and was prejudicial to her development.
- Similar aggravating circumstances were present as in the first case.
Trial Proceedings
Prosecution's Evidence:
- Established that appellant sexually abused AAA on two separate occasions.
- The first incident involved caressing, thr