Case Summary (G.R. No. 225059)
Applicable Law
The case involves the application of provisions from the Revised Penal Code (RPC), particularly Article 266-A, paragraph 1, which defines the crime of rape, as amended by Republic Act No. 8353, also known as the Anti-Rape Law of 1997.
Factual Background
The accused, XXX, was indicted in four separate criminal cases for the rape of his daughter, BBB, based on accusations that occurred between 2004 and May 18, 2010. Each information detailed acts of sexual intercourse against her will, involving intimidation and the use of a deadly weapon. BBB testified that these incidents of sexual abuse began when she was 14 years old and included threats to kill her mother if she reported the acts.
Proceedings in Regional Trial Court
Upon arraignment, XXX pleaded not guilty, and trial commenced. The RTC found BBB's testimony credible against XXX's denial of the charges. The RTC established that BBB's accounts were consistent and substantiated by her references to physical abuses and threats, resulting in XXX’s conviction for all four counts of rape, with a penalty of reclusion perpetua for each charge and monetary damages awarded to BBB.
Court of Appeals Decision
XXX appealed the RTC's decision, raising several points including BBB's alleged failure to resist during the attacks and delays in reporting the incidents. The Court of Appeals upheld the RTC's ruling, re-affirming the findings of guilt. The CA emphasized that BBB's testimony, bolstered by medical evidence, was credible, detailing the violent circumstances under which the rapes occurred and dismissing XXX's arguments as insufficient.
The Supreme Court's Ruling
The Supreme Court ruled that proof beyond a reasonable doubt had been established, affirming BBB's testimony's credibility while maintaining that the accused's defense lacked substantial corroboration. The Court ruled that the psychological impact of abuse, along with the inherent vulnerability of a minor, often complicates immediate reporting and should not undermine the victim's credibility.
Guilt and Penalty Confirmation
The evidence presented was deemed sufficient to sustain a conviction for rapes committed against a minor, specifically noting that moral ascendancy, familial ties, and intimidation were crucial factors influencing the victim's delayed reporting. Consequently, the Supreme Court increased the damages awarded to BBB in accordance with prevailing jurisprudence, reinforcing the legal precedent of punishing sexual crimes against minors severely.
Damages Awarded
For Criminal Case No. 671-V-10, XXX was ordered to pay ₱75,000 e
...continue readingCase Syllabus (G.R. No. 225059)
Case Background
- This case involves an appeal filed under Section 13(c), Rule 124 of the Rules of Court from a decision of the Court of Appeals dated July 24, 2015.
- The appeal challenges the Joint Decision dated July 10, 2012, of the Regional Trial Court (RTC) of Valenzuela City, which convicted the accused-appellant XXX of four counts of rape.
- The case pertains to four separate Informations for rape filed against XXX under Articles 266-A and 266-B of the Revised Penal Code.
Charges and Allegations
- Criminal Case No. 671-V-10: Allegations of rape committed on May 18, 2010, where XXX, the father of the complainant BBB, allegedly used force and intimidation to have sexual intercourse with her.
- Criminal Case No. 672-V-10: Allegations of rape committed in 2005, where the victim was 15 years old at the time, and this was the second incident of rape.
- Criminal Case No. 673-V-10: Another count of rape in 2005, again involving the victim who was 15 years old, marking the third incident.
- Criminal Case No. 674-V-10: Allegations of rape committed in 2004, where the victim was 14 years old, marking the first incident of abuse.
Procedural History
- Upon arraignment, XXX pleaded "not guilty" to all charges, and trial followed.
- The prosecution's version included detailed accounts from BBB, who testified about the repeated sexual assaults by her father.
- The RTC found XXX guilty based on BBB’s credible testimony and imposed the penalty of reclusion perpetua for each count of rape, along with damages.