Case Summary (G.R. No. 224626)
Factual Background
YYY faced three separate charges of rape under Article 335 of the Revised Penal Code, with the incidents occurring on different dates between 1993 and 1994, when AAA was between nine and ten years old. During his arraignment on September 3, 2001, YYY entered a plea of "Not Guilty." The prosecution presented testimony from AAA detailing the incidents of sexual assault, emphasizing the use of force, intimidation, and threats against her.
Version of the Prosecution
AAA recounted that YYY would call her, threaten her, and force her into submission, resulting in forced sexual acts. AAA testified that during the incidents, she was unable to resist or seek help due to YYY’s threats and intimidation. A medical examination later revealed physical evidence consistent with the acts of rape.
Version of the Defense
YYY denied the allegations, claiming he was not present during the incidents and asserting that AAA's testimony was fabricated. He claimed that the prosecution failed to provide corroborative evidence and that AAA’s account appeared rehearsed.
RTC Ruling
On April 23, 2012, the RTC found YYY guilty of three counts of rape and sentenced him to reclusion perpetua, citing AAA's consistent and credible testimony. It rejected YYY’s defenses, emphasizing that familial relationships and threats played significant roles in AAA's decision to delay reporting the crimes. The RTC awarded moral damages, civil indemnity, and exemplary damages to AAA.
CA Ruling
The CA affirmed the RTC's decision with modifications, agreeing that AAA's testimony effectively established the elements of rape and reducing the charges from qualified to simple rape due to the lack of an allegation of relationship in the informations. The CA modified the damage awards to align with precedents.
Issues on Appeal
YYY raised two primary issues: the credibility of AAA’s testimony and the lack of corroborative evidence to support her claims. He argued that the trial court had erred in its assessment and that AAA's account was implausible.
Court's Ruling
The Supreme Court upheld the conviction, affirming that a victim’s testimony suffices to establish the elements of rape even without corroborative evidence. It emphasized that AAA's straightfor
...continue readingCase Syllabus (G.R. No. 224626)
Case Background
- This case pertains to an appeal from the Court of Appeals' decision dated November 11, 2015, which modified the Regional Trial Court's consolidated judgment.
- The accused-appellant, YYY, was found guilty of three counts of Rape against his half-sister, AAA, under Article 335 of the Revised Penal Code.
- The events leading to the trial involved incidents of sexual abuse occurring on three separate occasions in 1993 and 1994.
Factual Overview
- YYY was charged with three counts of rape as follows:
- Criminal Case No. 2K-CR-3865: Involving an incident on March 26, 1994, where AAA was ten years old.
- Criminal Case No. 2K-CR-3866: Involving an incident on June 17, 1993, where AAA was nine years old.
- Criminal Case No. 2K-CR-3867: Involving another incident on September 11, 1993, where AAA was also nine years old.
- Each Information detailed the accused's use of force, violence, and intimidation to have carnal knowledge of AAA against her will.
Prosecution's Version
- AAA testified that YYY assaulted her in three instances:
- First Incident: On June 17, 1993, YYY called AAA to massage him, undressed her, and forced her to lie down, during which he covered her mouth with a handkerchief and raped her while threatening her life.
- Second Incident: On September 11, 1993, YYY carried AAA, laid her on a carton, and raped her despite her attempts to resist. She later ran to her father but was too afraid to explain.
- Third Incident: On March 26, 1994, YYY undressed AAA while she was sleeping and raped her after pulling her to a corner and threatening her.
- In 2000, AAA reported the rapes after discovering YYY was also abusing her younger sister.
- Medical examination revea