Case Summary (G.R. No. 225781)
Factual Background
The accused-appellant was charged with two counts: Rape (Criminal Case No. 692-06-P) for an incident on December 25, 2005, and Attempted Rape (Criminal Case No. 691-06-P) for an incident on January 5, 2006. In the first case, it was alleged that XXX, armed with a bladed weapon, forcibly had carnal knowledge of the victim. In the second case, he attempted to commit rape but was interrupted when the victim's mother arrived and intervened.
Procedural History
Upon arraignment, the accused pleaded not guilty. The prosecution presented the victim, her mother, and a physician as witnesses. Initially, the victim provided a Sinumpaang Salaysay ng Pag-uurong ng Habla indicating her desire to withdraw from the case, claiming misunderstandings. Despite this, she later testified against the accused during the trial.
Prosecution's Version
The prosecution contended that on December 25, 2005, while the victim was home alone, XXX returned and forcibly undressed AAA, threatened her with a weapon, and raped her. Medical examination corroborated the victim's testimony, revealing injuries consistent with abuse. On January 5, 2006, he attempted to rape the victim again but was interrupted by her mother.
Defense's Version
The defense argued that the accused was not present during the December incident and pointed to the victim's affidavit of desistance as evidence of her lack of interest in pursuing charges. XXX claimed the victim's allegations were prompted by her mother’s influence.
Ruling of the Regional Trial Court
On January 21, 2014, the Regional Trial Court acquitted the accused of Attempted Rape but convicted him of Rape, sentencing him to reclusion perpetua and ordering him to pay civil indemnity and moral damages to the victim. The court found the victim’s testimony credible and consistent despite the retraction.
Ruling of the Court of Appeals
The Court of Appeals upheld the Regional Trial Court's decision on September 24, 2015, emphasizing that recantations are generally viewed with suspicion, particularly in sexual assault cases. They affirmed the findings of fact and law of the lower court.
Issue
The sole issue on appeal was whether the prosecution had proven the accused's guilt beyond a reasonable doubt for the crime of Rape as charged.
Court's Analysis
The Supreme Court affirmed the accused-appellant’s conviction, noting that the essential elements of Rape—carnal knowledge through force and intimidation—were adequately established through the victim’s unyielding testimony and medical evidence. The retraction by the victim was deemed unreliable, as recantations in rape cases can be influenced by external pressures.
Correction of Designation and Penalties
The court fou
...continue readingCase Syllabus (G.R. No. 225781)
Case Background
- The case involves an appeal from the accused-appellant, XXX, challenging the September 24, 2015 Decision of the Court of Appeals (CA) affirming the January 21, 2014 Joint Decision of the Regional Trial Court (RTC), Branch 38 of San Jose City, Nueva Ecija.
- The RTC found the accused-appellant guilty beyond reasonable doubt of the crime of Rape under Article 266-A of the Revised Penal Code (RPC), in relation to Republic Act No. 7610, the Special Protection of Children Against Child Abuse, Exploitation and Discrimination Act.
Charges and Allegations
- XXX faced two separate Informations:
- Criminal Case No. 692-06-P alleged Rape committed on December 25, 2005, against AAA, a minor aged 14, using a bladed weapon and occurring in the victim's residence during nighttime.
- Criminal Case No. 691-06-P alleged Attempted Rape on January 5, 2006, where the accused attempted to rape AAA, also using a kitchen knife, but was interrupted by the mother of the victim, BBB.
Proceedings and Testimonies
- Upon arraignment, the accused-appellant pleaded not guilty.
- The prosecution's case included testimonies from the victim AAA, her mother BBB, and physician Dr. Ma. Eilyn F. Basco, who conducted the medical examination.
- The defense presented XXX as its sole witness, who denied the allegations and cited the victim’s affidavit of desistance dated November 26, 2013, expressing her lack of interest in pursuing the case.
Prosecution's Version
- On December 25, 2005, while BBB was away,