Title
Supreme Court
People vs. Benny Dalaguet
Case
G.R. No. 249414
Decision Date
Jul 27, 2022
Benny Dalaguet convicted of two counts of lascivious conduct against a minor, affirmed by Supreme Court despite his denial; credible testimony and evidence upheld.

Case Summary (G.R. No. 249414)

Facts

  1. In December 2009, while AAA pastured animals in a family “payag-payag,” Dalaguet followed her into a hut, carried her inside, undressed her and himself, and performed lewd acts—pushing his penis against the outside of her vagina—without penetrating. She struggled and shouted but could not escape.
  2. On March 9, 2010, left alone with her sister away at school, AAA was again held, undressed, and subjected to similar acts. Her grandfather, EEE, intervened and caught Dalaguet in the act; Dalaguet threatened to kill him but fled.
  3. AAA’s medical examination on March 10, 2010, showed healed lacerations of the genitalia. AAA’s birth certificate established her age as 15.

Procedural History

  • March 29, 2010: Two Informations filed charging rape under Section 5(b), R.A. 7610 (criminal cases F-10-49-MJ and F-10-50-MJ).
  • July 13, 2016 (RTC, Branch 45, Bais City): Convicted Dalaguet of two counts of rape, sentenced to reclusion perpetua (20 years + 1 day to 40 years) per count, and awarded damages of ₱100,000 actual and ₱100,000 moral.
  • June 25, 2019 (Court of Appeals): Modified conviction to two counts of lascivious conduct under Section 5(b), R.A. 7610, sentencing to eight (8) years + 1 day to 17 years 4 months + 1 day per count, plus ₱50,000 each of civil indemnity, moral and exemplary damages per count.
  • July 29, 2019: Appeal to the Supreme Court.

Issue

Did the Court of Appeals err in convicting Dalaguet of lascivious conduct under Section 5(b), R.A. 7610, in lieu of rape, despite the lack of proof of penile penetration?

Analysis and Ruling

  1. Credibility of the Victim’s Testimony

    • The sole testimony of a sexual-abuse victim, if clear, positive and convincing, suffices for conviction. The trial court’s assessment of witness demeanor is accorded great respect.
    • AAA’s consistent account of force, coercion, non-consent and physical struggle established the elements of a sexual offense. Her delay in reporting and lack of shouting do not negate fear-induced submission.
  2. Rape Through Sexual Intercourse (RPC Art. 266-A(1)(a))

    • Elements: (a) carnal knowledge and (b) force/threat/intimidation. Penetration, even slight (touching of the labia), is indispensable.
    • AAA categorically testified that Dalaguet’s penis did not penetrate her vagina, only contacted the external area. Medical findings showed healed (not fresh) lacerations, insufficient to prove consummated rape.
  3. Lascivious Conduct under R.A. 7610, Section 5(b)

    • Elements: (a) sexual intercourse or lascivious conduct; (b) victim is a child below 18 subjected to coercion or influence; (c) victim under 18.
    • AAA testified that Dalaguet made her lie down, undressed both of them, and performed lewd acts against her will on two occasions. She was 15 and unable to resist effectively. Coercion and influence were present.
    • The variance doctrine permits conviction for a necessarily included offense proven at trial. Lascivious conduct is necessarily included in rape when penetration is not established.
  4. Applicability of R.A. 11648 (Age of Consent Raised to 16)

    • R.A. 11648’s higher age of consent and modified pena

...continue reading

Analyze Cases Smarter, Faster
Jur is a legal research platform serving the Philippines with case digests and jurisprudence resources. AI digests are study aids only—use responsibly.