Case Summary (G.R. No. 252865)
Preliminary Information
The accused, YYY, faced five separate charges filed as Criminal Case Nos. 09-1411, 09-1412, 09-1413, 09-1414, and 09-1415. The charges, based on allegations of Statutory Rape under Article 266-A of the Revised Penal Code (RPC), as amended by Republic Act No. 8353, were specifically leveled against YYY for acts committed against his minor nieces. Notably, the accusations pertained to occurrences on January 24, 25, and 26, 2007.
Proceedings and Trial
Upon arraignment on August 25, 2009, YYY pleaded not guilty. The prosecution presented a detailed account of the events leading to the charges, showcasing that the accused acted as the victims' uncle and misused that trust to commit the offenses. Victims AAA and BBB testified about the incidents, confirming that YYY engaged in sexual acts with both, leading to substantial distress and suffering.
Evidence Presented
In conjunction with testimonies from the young victims, the prosecution provided a medico-legal report, although it indicated no recent injuries. Victims AAA and BBB still conveyed that they felt pain during the incidents. The defense, on the other hand, relied on the accused's denial and asserted a lack of substantial evidence against him, claiming the charges arose from a familial dispute.
RTC Decision
On February 13, 2018, the RTC convicted YYY of four counts of Statutory Rape while acquitting him for one count attributed to AAA. The RTC imposed a sentence of reclusion perpetua for the four counts and mandated payment of civil indemnity and moral damages to both victims.
CA Ruling
The CA affirmed the RTC decision in its October 1, 2019 ruling. It modified the damage amounts awarded, recognizing the age of the victims and further assessing the impact of the crimes on their lives. The apportionment of damages was adjusted, and harsher penalties were aligned with the nature of charges confirmed against BBB and AAA, classified appropriately under the existing laws.
Appeals and Issues Raised
YYY appealed against the conviction, arguing the prosecution’s failure to sufficiently demonstrate his actions under discerning legal provisions, asserting doubt on the evidence's adequacy. He challenged the credibility of the victims' testimonies, proposing that his alibi was credible, while the prosecution’s evidence was insufficient.
Supreme Court's Ruling
The Supreme Court dismissed the appeal, reiterating the nature of Statutory Rape under Philippine law which does not require evidence of discernment if the victim is below twelve years old. The Court solidified that the prosecution had established the elements of the crime beyond a reasonable doubt via credible eyewitness accoun
...continue readingCase Syllabus (G.R. No. 252865)
Case Overview
- The case involves an appeal filed by YYY (accused-appellant) contesting the Decision dated October 1, 2019, of the Court of Appeals (CA), which affirmed the ruling of the Regional Trial Court (RTC) finding him guilty beyond reasonable doubt of four counts of Statutory Rape.
- The case is recorded under G.R. No. 252865 and was decided on August 4, 2021, by the Second Division of the Supreme Court of the Philippines.
Antecedents
- The case originated from five separate Informations filed in the RTC, detailing charges against YYY for Statutory Rape as defined under Article 266-A paragraph (1)(d) of the Revised Penal Code (RPC), amended by Republic Act No. 8353.
- The victims, AAA and BBB, were two years old and eight years old, respectively, at the time of the alleged offenses.
- The Informations explicitly outlined the dates and circumstances under which the crimes were said to have occurred.
Charges Filed
- Criminal Case No. 09-1411: Alleged rape of AAA on January 24, 2007.
- Criminal Case No. 09-1412: Alleged rape of BBB on January 24, 2007.
- Criminal Case No. 09-1413: Alleged rape of AAA on January 25, 2007.
- Criminal Case No. 09-1414: Alleged rape of BBB on January 25, 2007.
- Criminal Case No. 09-1415: Alleged rape of BBB on January 26, 2007.
Prosecution's Version
- The prosecution's evidence included the testimonies of the victims, who described the assaults by their uncle, YYY, during a time when they were under his