Case Summary (G.R. No. 197831)
Charges and Background
By Information dated February 28, 2017, the accused-appellant was charged with the crime of rape, alleging that on December 10, 2016, he assaulted AAA264352 with force and intimidation, engaging in non-consensual sexual intercourse. Upon arraignment, he pleaded not guilty, and the case proceeded to trial.
Prosecution's Case
The prosecution presented several witnesses including AAA264352, her daughter CCC264352, and Dr. Medardo S. Estanda. The complainant testified that she was attacked at night while asleep, during which the accused-appellant forcibly subdued her, removed her clothing, and raped her. Her daughter corroborated this account, stating she found her mother in distress and that they subsequently reported the crime to the police. Dr. Estanda's examination revealed the presence of spermatozoa in AAA264352’s vagina, consistent with sexual intercourse.
Defense's Argument
The defense centered around a denial of the accusations, with the accused-appellant claiming he was at a cockpit from 10:30 p.m. to 4:00 a.m., attempting to establish an alibi. His singular testimony was presented without additional evidence to support his claims.
Trial Court's Judgment
In its decision dated May 16, 2018, the trial court found the accused-appellant guilty beyond reasonable doubt. The court indicated that it believed AAA264352's testimony due to its detail and consistency. The court imposed a sentence of reclusion perpetua and ordered the payment of damages totaling PHP 300,000, divided equally among civil indemnity, moral damages, and exemplary damages.
Court of Appeals Review
The accused-appellant appealed the trial court's decision, arguing inconsistencies in the complainant’s testimony and claiming that the absence of physical injuries contradicted the occurrence of rape. In contrast, the Office of the Solicitor General asserted that the evidence, particularly the medical report, corroborated the prosecution's claims. The Court of Appeals ultimately affirmed the conviction but modified the monetary damages to PHP 75,000 for each category.
Supreme Court Findings
Upon reviewing the appeal, the Supreme Court confirmed that the prosecution had met its burden of proof, establishing the elements of rape as defined under Article 266-A of the Revised Penal Code, specifically that there was carnal knowledge accomplished through force and intimidation. The testimony of AAA264352 was deemed credible and was corroborated by medical evidence, leading the court to reject the defense's claims of denial and alibi.
Penalty and Financial Awards
The Supreme Co
...continue readingCase Syllabus (G.R. No. 197831)
Case Background and Charges
- Accused-appellant XXX264352 was charged by Information dated February 28, 2017, with rape under Article 266-A(1) in relation to Article 266-B of the Revised Penal Code.
- Incident alleged to have occurred on or about December 10, 2016, at 10:30 p.m., in the City of xxxxxxxxxxx, Philippines.
- The charge states that the accused, by means of force, threat, and/or intimidation, unlawfully and feloniously had carnal knowledge of the complainant AAA264352, against her will and without her consent.
- Upon arraignment, the accused pleaded not guilty, and trial ensued.
Facts Presented by the Prosecution
- Complainant AAA264352, aged 69, testified that accused-appellant was her brother-in-law and that on the night in question, he forcibly entered her house.
- She was sleeping when the accused grabbed her hands, pushed her against the wall, twisted her arm causing her to drop her bolo (a cutting weapon).
- Despite attempts to fend him off using the bolo, the accused forced her onto the bed, pulled her legs apart, laid on top of her, and had sexual intercourse by inserting his penis in her vagina.
- Accused warned her not to close the door as he would return.
- AAA264352's daughter, CCC264352, testified that she was awakened by her younger sister due to her mother’s groans, found her mother crying in pain, and was told about the rape.
- The incident was promptly reported to the police.
- Dr. Medardo S. Estanda conducted a medical and physical examination of AAA264352 on December 12, 2016, finding spermatozoa in the vagina indicative of previous sexual intercourse.
Defense Testimony
- The accused denied the charge and presented an alibi, testifying that he was at a cockpit from 10:30 p.m. to 4:00 a.m. on the night alleged.
- He contended he could not have committed the rape given his supposed whereabouts.
Trial Court Ruling
- The Regional Trial Court, Branch 55, xxxxxxxxxxx, Negros Occidental, rendered a Decision on May 16, 2018, finding accused-appellant guilty beyond reasonable doubt of rape.
- Sentenced to reclusion perpetua.
- Ordered to pay PHP 100,000 each as civil indemnity, moral damages, and exemplary damages, all with 6% interest per annum from finality until full payment.
- The court gave full credence to AAA264352’s testimony, highlighting her positive, detailed, and candid narration.
- The accused’s denial was found weak and unconvincing.
Appeal to the Court of Appeals
- The accused appealed, challenging the credibility and consistency of the complainant’s testimony.
- Argued medical evidence (Living Case Report) showed no vaginal lacerations or