Case Summary (G.R. No. 259221)
Background of the Case
The accused-appellant faced charges in two separate Informations: one for Rape and another for Attempted Rape, based on Article 266-A of the Revised Penal Code (RPC) and Republic Act No. 7610. The allegations stemmed from incidents occurring on December 25, 2005, and January 5, 2006. In the first incident, the accused-appellant, armed with a bladed weapon, forcibly had carnal knowledge of the victim, a 14-year-old girl. The second incident involved an attempt to rape the same victim but was interrupted when her mother intervened.
Proceedings and Evidence
Upon arraignment, the accused-appellant pleaded not guilty. During the trial, the prosecution presented the victim, her mother (BBB), and a physician (Dr. Ma. Eilyn F. Basco) as witnesses. The victim established a detailed account of the incidents, recounting her horrific experiences and the threats made by the accused-appellant. Conversely, the defense relied on the accused-appellant's testimony, who claimed he was not present during the alleged incidents and presented the victim's affidavit of desistance that indicated her withdrawal of accusations against him.
Findings of the Regional Trial Court
On January 21, 2014, the RTC acquitted the accused-appellant of Attempted Rape but convicted him of Rape in the first Criminal Case. The court found substantial evidence supporting the victim's testimony and issued a sentence of reclusion perpetua, accompanied by civil indemnity and moral damages.
Ruling by the Court of Appeals
The Court of Appeals reaffirmed the RTC's decision on September 24, 2015, highlighting the credibility of the victim's testimony despite her later recantation. The court emphasized that retractions in sensitive cases like rape are often unreliable, especially when substantial evidence is already presented.
Evaluation of the Rape Charge
The conviction of the accused-appellant for the crime of Rape hinges on the established elements under Article 266-A of the RPC, which includes the commission of carnal knowledge through force or intimidation. The victim's testimony, corroborated by medical findings of trauma, formed the backbone of the prosecution's case.
Rejection of Recantation
The appellate court maintained that the victim's earlier recantation could not undermine her detailed initial testimony, delivered in a consistent manner over multiple hearings. A significant period elapsed before her retraction, which raised doubts about its reliability, evidencing that it may have been influenced by external factors.
Modification of Conviction
While affirming the guilty verdict, the Supreme Court adjusted the designation of the crime to align solely under Article 266-A of the RPC, excluding the correlation to Republic Act 7610, which had been erroneously includ
...continue readingCase Syllabus (G.R. No. 259221)
Case Background
- The case involves an appeal by accused-appellant XXX, challenging the September 24, 2015 Decision of the Court of Appeals (CA) in CA-GR CR HC No. 06715.
- The CA affirmed the January 21, 2014 Joint Decision of the Regional Trial Court (RTC), Branch 38 of San Jose City, Nueva Ecija, which found XXX guilty of Rape.
- XXX was charged in two separate Informations for Rape and Attempted Rape under Article 266-A of the Revised Penal Code (RPC) and Republic Act No. 7610 (Special Protection of Children Against Child Abuse, Exploitation and Discrimination Act).
Charges and Facts of the Case
- Criminal Case No. 692-06-P:
- Date: December 25, 2005
- Location: Province of Nueva Ecija
- Accused-appellant allegedly committed Rape against AAA, a 14-year-old minor, using a bladed weapon and force.
- Criminal Case No. 691-06-P:
- Date: January 5, 2006
- Allegation of Attempted Rape against the same victim, which was interrupted when the victim's mother, BBB, arrived and confronted the accused.
Trial Proceedings
- Upon arraignment, XXX pleaded not guilty.
- The prosecution's witnesses included AAA, her mother BBB, and physician Dr. Ma. Eilyn F. Basco.
- The defense presented XXX as its sole witness.
- In a significant turn, AAA executed an affidavit of desistance on November 26, 2013, expressing a desire to retract her accusations, claiming they resulted from misunderstandings and pressure from her mother.
Testimonies Presented
Prosecution's Version:
- On December 25, 2005, while BBB was away, XXX returned home, assaulted AAA, and raped her while threatening her with a bladed weapon.
- On January 5