Case Summary (G.R. No. 240441)
Applicable Law
The pertinent laws include Republic Act No. 7610 (R.A. 7610) concerning child abuse and exploitation, and the Revised Penal Code (RPC), particularly the provisions on rape under Article 266-A.
Charges and Background
XXX faced separate charges—Criminal Case No. IR-7893 for lascivious conduct against BBB, a 14-year-old, and Criminal Case Nos. IR-7957 and IR-7958 for statutory rape and rape against AAA, who was 8 years old at the time of the first incident and 13 during the second. The incidents occurred in Iriga City, Philippines, involving alleged sexual abuses that took place in 1998, 2002, and 2006.
Trial and Evidence
During the trial, the testimonies of the victims were presented, detailing the acts of sexual abuse. AAA testified that XXX had threatened her as a means of coercion during the two separate instances of rape, while BBB described a separate incident of lascivious conduct. The victims' ages were substantiated through birth certificates.
Defense Claims
XXX denied the charges, arguing inconsistencies in the victims' testimonies regarding timelines and their ages. He provided an alibi that he was not present during the incidents and challenged the absence of physical coercion. He claimed that the accusations arose from a manipulation by BBB's neighbor.
Ruling of the RTC
The RTC found XXX guilty beyond a reasonable doubt of violating R.A. 7610 and committed statutory rape, imposing severe penalties including reclusion perpetua and various damages to both victims. The RTC held that moral ascendancy constituted sufficient intimidation in these cases, given the family relationship.
Ruling of the CA
The CA upheld the RTC’s judgment but made notable modifications. It determined that XXX's relationship to the victims as a mere common-law spouse rather than a stepfather influenced the classification of the rape charges, arguing that proof must be firmly established based on the allegations in the Information. The CA affirmed the convictions for simple rape while increasing some damage awards.
Key Legal Principles
The caselaw highlights the distinct definitions of "common-law spouse" and "step-parent," emphasizing that the grave nature of the charges necessitates precise legal definitions. The court maintained that in statutory rape cases, the age and the absence of valid consent are the critical factors for establishing culpability, thus diminishing the importance of force and th
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Case Overview
- Court: Second Division, Supreme Court of the Philippines
- Case Number: G.R. No. 240441
- Date of Decision: December 4, 2019
- Parties: People of the Philippines (Plaintiff-Appellee) vs. XXX (Accused-Appellant)
Background of the Case
- The accused, XXX, faced multiple charges:
- Criminal Case No. IR-7893: Violation of Section 5(b), Article III of R.A. No. 7610 (Lascivious Conduct)
- Criminal Case No. IR-7957: Statutory Rape under Article 266-A, paragraph 1(d) of the Revised Penal Code (RPC)
- Criminal Case No. IR-7958: Rape under Article 266-A, paragraph 1(a) of the RPC
- The crimes were committed against his stepdaughter AAA and another minor, BBB.
Details of the Crimes
Criminal Case No. IR-7893:
- Date: December 2, 2006
- Location: Inside their house in Iriga City.
- Incident: XXX pulled BBB's blanket, touched her breasts and legs, causing psychological trauma.
Criminal Case No. IR-7957:
- Date: August 1998
- Location: Banana plantation in Iriga City.
- Incident: XXX, armed with a bolo, threatened AAA and forcibly had carnal knowledge of her when she was eight years old.
Criminal Case No. IR-7958:
- Date: April 2002
- Location: Coconut kiln in Iriga City.
- Incident: XXX again threatened AAA, who was thirteen years old, and forced her into sexual intercourse.
Proceedings and Rulings
- XXX pleaded not guilty, leading to a trial where the prosecution presented testimonies from both AAA and BBB.
- The Regional Trial Court (RTC) convicted XXX, imposing severe penalties, including reclusion perpetua and financial compensation to the victims.
Rulings of the RTC and Court of Appeals (CA)
RTC R