Case Summary (G.R. No. 229862)
Procedural History
The case began with the filing of an Information against ZZZ on May 23, 2006, charging him with the crime of rape under Article 266-A of the Revised Penal Code. ZZZ pleaded not guilty during his arraignment on July 19, 2006. The Regional Trial Court convicted him on June 25, 2013, of simple statutory rape, a conviction that was upheld by the Court of Appeals on September 30, 2016. ZZZ subsequently appealed to the Supreme Court.
Allegations and Testimonies
AAA testified that on April 12, 2006, after falling asleep, she awoke to find ZZZ undressed and on top of her. She described inappropriate touching and penetration, indicating the violent and coercive nature of the act. The medical examination conducted by Dr. Edalin Dacula corroborated AAA's testimony, finding abrasions consistent with sexual intercourse.
Defense Strategy
The defense called witnesses, including AAA's mother, BBB, who testified about her relationship with ZZZ and the circumstances surrounding the alleged incident. ZZZ denied committing rape, suggesting that the accusations were influenced by family disputes. He also presented AAA's affidavit of recantation, in which she claimed that the allegations were made under duress.
Trial and Conviction
The Regional Trial Court found ZZZ guilty, noting the lack of evidence supporting AAA's minority status but affirming her testimony's credibility and consistency. The trial court ruled that the prosecution had established that AAA was raped and that the presence of moral ascendancy sufficed to satisfy the requirement of intimidation in rape cases where the accused holds a position of authority over the victim.
Court of Appeals Decision
The Court of Appeals affirmed the trial court's decision, clarifying that the use of "statutory" to describe the rape was erroneous but did not alter the overall verdict. The appellate court emphasized the sufficiency of AAA's testimony, which disclosed a vivid and coherent sequence of events. Importantly, it rejected ZZZ's arguments regarding the lack of force and intimidation due to the moral influence exerted by him as a common-law husband.
Supreme Court Findings
Upon reviewing the case and the arguments of both parties, the Supreme Court upheld the lower courts' decisions. It emphasized the prosecution's success in proving the elements of rape beyond a reasonable doubt, reaffirming the victim's credibility and the admissibility of moral
...continue readingCase Syllabus (G.R. No. 229862)
Case Overview
- This case involves ZZZ, who is accused of committing rape against AAA, a minor and the daughter of his common-law spouse.
- The crime allegedly occurred on April 12, 2006, in the City of xxxxxxxxxxx, Philippines.
- ZZZ was charged with rape under Article 266-A, in relation to Article 266-B of the Revised Penal Code.
- ZZZ pleaded not guilty during his arraignment on July 19, 2006.
Background of the Case
- An Information was filed against ZZZ on May 23, 2006, charging him with rape by means of force and intimidation.
- The prosecution presented AAA and Dr. Edalin Dacula as witnesses during the trial.
- AAA's testimony detailed the events of the day of the incident, including accusations of ZZZ committing sexual acts upon her while she was asleep.
Testimonies and Evidence
AAA's Testimony:
- AAA stated she fell asleep after doing laundry and awakened to find ZZZ on top of her.
- ZZZ was described as having his lower body naked and forcing AAA to touch him.
- Further actions included penetration and various sexual acts that AAA described vividly.
Dr. Edalin Dacula's Testimony:
- Conducted a medical examination on AAA and found signs of trauma, specifically redness and abrasion on AAA's labia minora, indicative of sexual assault.
Defense's Argument:
- Witnesses included AAA's mother, who testified about her actions after returning home and finding ZZZ and AAA together.
- ZZZ presented his side, claiming no wrongdoing and suggested that he was framed due to family issues.
- An Affidavit of