Case Summary (G.R. No. 247750)
Charges and Background
The accused was charged in Criminal Case Nos. S-4290 and S-4291 for Rape, committed against AAA, who was a 16-year-old with a mental disability. The charges stemmed from incidents in May 2009, where it was alleged that YbaAez exploited AAA’s condition by asserting that sexual intercourse would “cure” her epilepsy.
Proceedings Before the RTC
During the trial, AAA's testimony detailed multiple incidents of sexual assault occurring under the guise of medical treatment provided by YbaAez, who presented himself as a quack doctor. AAA's mother, upon discovering her daughter’s plight, confronted YbaAez, leading to his arrest.
RTC Ruling
The RTC acquitted YbaAez in Criminal Cases S-4292 and S-4225 due to reasonable doubt but convicted him in S-4290 and S-4291. The RTC acknowledged AAA's mental disability and concluded that YbaAez had acted with malice and fraudulent intent, ruling that his advanced age did not exempt him from liability. YbaAez was sentenced to reclusion perpetua for the two counts of Rape, with damages awarded to AAA.
Appeal to the Court of Appeals
YbaAez appealed the RTC decision, contesting the sufficiency of the evidence and AAA's credibility. The CA affirmed the conviction but modified the damages awarded to AAA, reducing the monetary compensation.
Supreme Court’s Review
Upon Supreme Court review, the principal issue was whether YbaAez's actions constituted Qualified Rape, considering his knowledge of AAA's mental disability. The Court recognized a discrepancy in the classification of the Crime as merely Rape rather than Qualified Rape, which carries a heavier penalty due to the presence of a qualifying circumstance under Article 266-B of the Revised Penal Code.
Findings on Qualified Rape
The Supreme Court emphasized that for the crime to be classified as Qualified Rape, the prosecution needed to prove that YbaAez knew of AAA's mental disability at the time of the offenses. Due to compelling evidence presented during the trial, which demonstrated YbaAez's awareness of AAA’s condition and his fraudulent machination, the Court concluded that the elements of Qualified Rape were satisfied.
Criminal Liability and Penalty
Despite YbaAez's advanced age, which typically could be considered a mitigating circumstance, the Court imposed the penalty of reclusion perpetua withou
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Case Overview
- The case involves an appeal by Maximo Dinoy YbaAez (accused-appellant) against the Decision dated April 3, 2019, of the Court of Appeals (CA) in CA-G.R. CR-HC No. 01919-MIN.
- The CA affirmed with modification the Joint Decision dated February 26, 2018, of Branch 11, Regional Trial Court (RTC), Sindangan, Zamboanga del Norte in Criminal Case Nos. S-4290, S-4291, S-4292, and S-4225.
- Accused-appellant was convicted of two counts of Rape but acquitted of two other charges.
Charges Against the Accused
- Accused-appellant faced the following charges:
- Criminal Case No. S-4290: Rape of AAA, a 16-year-old minor, on May 2, 2009, under Article 266-A of the Revised Penal Code (RPC) in relation to RA 7610.
- Criminal Case No. S-4291: Rape of AAA on May 4, 2009, the same provisions as above.
- Criminal Case No. S-4292: Rape of AAA on May 6, 2009, the same provisions as above.
- Criminal Case No. S-4225: Child Abuse under Section 10(a) of RA 7610 for acts on May 14, 2009.
Prosecution's Version of Events
- On May 2, 2009, AAA visited accused-appellant, who was known as a quack doctor treating her epilepsy.
- Accused-appellant allegedly manipulated AAA into believing that sexual intercourse would cure her epilepsy.
- He committed acts of sexual abuse on May 2, May 4, and May 6, 2009, under the pretense of treatment, causing her pain.
- On May 13, 2009, AAA disclosed the incidents to her mother, resulting in a confrontation with accused-appellant.
- Medical examinations confirmed signs of sexual abuse, including the absence of hymen.
Defense's Argument
- Accused-appel