Case Summary (G.R. No. 127904)
Charges and Allegations
Criminal Case No. Q-96-67322 alleges that Esteban Victor y Penis, as the stepfather of the victim Marilyn, committed qualified rape in May 1996. The allegations specify that he used force and intimidation while she was 13 years old, undressing her and engaging in sexual intercourse against her will. In Criminal Case No. Q-96-67323, he was further charged with acts of lasciviousness, which included molestation of the victim on August 5, 1996, also when the victim was 13 years old.
Trial and Testimonies
At the arraignment, the accused entered a plea of not guilty, leading to a consolidated trial. The prosecution presented witnesses, including the victim and a Medico-Legal Officer who examined her. Marilyn testified about the assaults and the conditions under which they occurred, detailing intimidation and threats made by the accused. Marilyn further explained that after the initial rape, the accused continued to sexually harass her, leading her to seek refuge with relatives.
Medical Examination
Dr. Rosaline O. Cosidon testified about her medical examination of Marilyn, which revealed physical evidence consistent with sexual abuse. The examination found significant injuries, including healed lacerations indicative of forced sexual intercourse, supporting the allegations of rape.
Defense and Accused’s Testimony
The defense, presented by Esteban, argued that he was not solely the stepfather as he claimed to have been married to Marilyn’s mother. He denied the accusations and reframed the relationship as that of a common-law partnership rather than a legal marriage, arguing that this distinction should mitigate the imposition of the death penalty. The court found his claims inconsistent, as there was no marriage certificate presented to substantiate his defense.
Decision of the Trial Court
The trial court found Esteban guilty beyond reasonable doubt of both charges. In the decision, it was noted that the relationship between the accused and the complainant, as well as evidence of intimidation and the use of a weapon during the commission of the rape, justified the imposition of the death penalty for qualified rape. The court also imposed penalties for the acts of lasciviousness.
Legal Analysis of Appeals
In the appeal, the accused contested the imposition of death on the grounds that the prosecution failed to prove his legal marriage to the victim's mother, thereby questioning the special qualifying circumstance of their relationship. The findings regarding the relationship status are critical since Article 335 of the Revised Penal Code provides that certain relationships elevate the crime to qualified rape.
Court's Findings on Relationship and Penalty
The court concluded that the prosecution did not sufficiently prove the existence of a legal marriage, which was necessary for categorizing the crime as qualified rape. As a result, the penalty was modified to reclusion perpetua, reflecting the special circumstances surrounding the victim's minority and the intention to intimidate h
...continue readingCase Syllabus (G.R. No. 127904)
Overview of the Case
- This case involves the automatic review of the decision rendered by Branch 95 of the Regional Trial Court in Quezon City, which found the accused-appellant Esteban Victor y Penis guilty beyond reasonable doubt of qualified rape and acts of lasciviousness.
- The court sentenced him to death for the qualified rape and imposed an indeterminate penalty for acts of lasciviousness along with monetary damages for the private complainant, Marilyn Corpuz Villanueva.
Background Information
- Criminal Case Numbers:
- Q-96-67322 for qualified rape.
- Q-96-67323 for acts of lasciviousness.
- Victim’s Age: The victim, Marilyn Villanueva, was 13 years old at the time of the incidents.
- Relationship: Esteban Victor y Penis was the stepfather of the victim, being the common-law husband of her mother, Julieta Corpuz.
Allegations
- Qualified Rape (Criminal Case No. Q-96-67322):
- The complaint alleged that in May 1996, while Julieta was out, accused-appellant undressed Marilyn, threatened her with a knife, and had carnal knowledge of her against her will.
- Acts of Lasciviousness (Criminal Case No. Q-96-67323):
- The complaint stated that on August 5, 1996, accused-appellant engaged in lewd acts with Marilyn, which included kissing her and touching her private parts unlawfully.
Trial Proceedings
- Plea and Trial:
- The accused-appellant entered a plea of not guilty during arraignment, leading to a joint trial.
- Witnesses:
- The prosecution presented Marilyn Villanueva and Dr. Rosaline O. Cosidon as witnesses. Marilyn provided detailed accounts of the incidents, while Dr. Cosidon conducted a medical examination of the victim.
Testimonies
- Marilyn Villanueva’s Testimony:
- Described the incidents of assault and the psychological