Case Summary (G.R. No. 207791)
Proceedings Before the Trial Court
The appellant was charged under six separate Informations for serious crimes including two counts of rape by carnal knowledge, one count of rape by sexual assault, two counts of acts of lasciviousness, and one count of violation of Section 5(c) of Republic Act No. 9262 (the Anti-Violence Against Women and Their Children Act of 2004). The charges stem from incidents occurring in August 2002 and 2006. The appellant pleaded not guilty and a joint trial commenced, during which the prosecution presented testimonies from the victims and supporting witnesses.
Prosecution's Evidence
Testimonies from AAA, BBB, and CCC revealed a pattern of sexual abuse perpetrated by the appellant from 2002 to 2006. AAA recounted the traumatic events of being raped and sexually assaulted on multiple occasions when left alone with her stepfather. Her accounts of the physical and emotional abuse she endured over the years were corroborated by the testimonies of her siblings and mother, DDD, as well as medical evidence indicating healed hymenal lacerations on AAA.
Defense's Evidence
The defense, however, relied on the appellant's denial of the allegations, claiming he was often working away from home and could not possibly have committed the crimes. The defense also attempted to discredit the victims' testimonies, asserting inconsistencies while failing to provide substantial counter-evidence. The court found such defenses inadequate and inherently weak in light of the overwhelming evidence presented by the prosecution.
Trial Court's Ruling
The trial court found the appellant guilty of the charges based on credible testimonies and evidence. The court imposed severe penalties including reclusion perpetua for the counts of rape and varying penalties for acts of lasciviousness and other violations. The court noted the relationship between the appellant and the victims, as well as their minority, as aggravating factors affecting the sentencing.
Proceedings Before the Court of Appeals
On appeal, the appellant contested the trial court's findings, arguing that the testimonies were implausible and lacked corroborative evidence. The Court of Appeals upheld the trial court's ruling, emphasizing the credibility of the victims and the significant evidence against the appellant. They noted that issues raised by the appellant mainly involved victim-blaming and misconceptions about the necessity of threats or violence given the inherent moral ascendancy he held over his stepchildren.
Court of Appeals' Ruling
The Court of Appeals affirmed the trial court’s ruling but modified some penalties, including adjustments in the civil damages awarded to the victims. The appellate court reinforced the grave nature of the offenses and stated that the appellant's actions constituted clear violations of both the Revised Penal Code and RA 9262, mandating supportive measures for the victims' welfare in light of his convictions.
Present Ap
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The Case
- This appeal concerns G.R. No. 230904, dated January 08, 2020, and addresses the conviction of the appellant for multiple sexual offenses, including two counts of rape by carnal knowledge, one count of rape by sexual assault, two counts of acts of lasciviousness, and a violation of Section 5(c) of Republic Act 9262.
- The decision being appealed stems from the Court of Appeals' ruling on December 12, 2016, which upheld the trial court’s verdict of conviction.
Proceedings before the Trial Court
The appellant, XXX, faced six Informations filed on August 8, 2006, detailing various charges:
- Criminal Case No. CR-06-8540: Rape by sexual assault involving AAA, the 17-year-old daughter of his common-law wife, where force and intimidation were used.
- Criminal Case No. CR-06-8541: Acts of lasciviousness against BBB, a 15-year-old daughter of his common-law wife, with similar motivations.
- Criminal Case No. CR-06-8542: Violation of Section 5(c) of RA 9262, where the accused attempted to cause physical harm to his children.
- Criminal Case No. CR-06-8543: Attempted rape against AAA, involving physical advances but not culminating in completed rape.
- Criminal Case No. CR-06-8544 and CR-06-8545: Two counts of rape by carnal knowledge against AAA, both involving force and intimidation.
During the trial, the prosecution presented testimonies from AAA, BBB, CCC, and DDD, establishing a pattern of abuse by the appellant.
Prosecution's Evidence
AAA's Testimony:
- Described her living situation with the appellant and detailed the first incident of rape on August 14, 2002, where she was threatened and physically overpowered.
- Recounted subsequent rapes and acts of sexual assault, emphasizing her fear of reprisals against her