Case Summary (G.R. No. 234841)
Facts of the Case
Manuel Barallas Ramilo was charged with violation of Article 266-A, paragraph 2, of the Revised Penal Code for rape through sexual assault on August 27, 2013. The Information against him outlined that he committed lascivious conduct against his daughter by inserting his fingers into her vagina through coercion and intimidation. Upon his arraignment, he pleaded not guilty, and a trial ensued. The prosecution presented several witnesses, including AAA, her sister BBB, the school principal, and police officers, all corroborating the incident, while Manuel denied the charges, alleging there was no unusual incident on the day in question.
Testimonies and Evidence
AAA provided a clear account of the event, detailing how her father threatened her if she reported the abuse. BBB testified about her concerns over AAA's changed behavior and past allegations of sexual abuse against their father by themselves or others, which led to significant emotional distress in the family. The school principal corroborated that AAA disclosed the abuse when prompted. Medical examinations revealed no physical injuries, but the court found the testimonies credible, emphasizing that the victim's narrative was direct and compelling.
Trial Court's Decision
On April 4, 2016, the Regional Trial Court (RTC) convicted Manuel of sexual assault and sentenced him to twelve years of prision mayor, with civil indemnities and damages awarded to the victim. The court placed significant weight on AAA’s testimony due to her age and the relationship between the victim and the accused, finding the defense's claims of fabrication and influence by family members unpersuasive.
Court of Appeals' Ruling
The Court of Appeals (CA), in its decision dated May 19, 2017, affirmed the RTC’s conviction with modifications on the awarded damages and interest. The CA underscored the credibility of AAA’s testimony, highlighting established legal principles which dictate that the testimony of child victims is often given greater credence.
Petition for Review
Manuel subsequently filed a petition for review, contending that the CA erred in sustaining his conviction, claiming the lack of corroboration and absence of physical injuries should negate the allegations against him. He further argued that AAA's behavior indicated a motive to fabricate charges against him.
Supreme Court's Findings
After reviewing the evidence and lower court decisions, the Supreme Court upheld the convictions of Manuel, initially finding his actions constituted sexual assault under Article 266-A of the Revised Penal Code. However, it was later determined that these acts would better fit the nomenclature of "Lascivious Conduct" under Republic Act No. 761
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Case Background
- The petition was filed by Manuel Barallas Ramilo seeking a review of the Court of Appeals' Decision dated May 19, 2017, and Resolution dated September 27, 2017, which affirmed the Regional Trial Court's (RTC) ruling.
- The RTC found Ramilo guilty beyond reasonable doubt of rape through sexual assault as defined under Article 266-A, paragraph 2 of the Revised Penal Code (RPC).
- The case stemmed from an Information filed on August 28, 2013, alleging that Ramilo committed sexual abuse and lascivious conduct against his twelve-year-old daughter, referred to as AAA.
Allegations and Charges
- The Information stated that on August 27, 2013, Ramilo, with lewd design and through force, threat, intimidation, and grave abuse of parental authority, sexually assaulted AAA by inserting his fingers into her vagina.
- The crime was aggravated by the relationship between Ramilo and the victim, being father and daughter.
Proceedings and Testimonies
- Ramilo pleaded not guilty during the arraignment and a pre-trial conference was held.
- The prosecution presented six witnesses, including AAA, her sister BBB, a school principal, a medico-legal officer, and investigating police officers.
- AAA testified that she had previously been molested by her father, which led to her fear of reporting the incidents.
Victim's Testimony
- AAA recounted that on the day of the incident, after waking up, Ramilo held her wrist and threatened her when she mentioned reporting him.
- He then forced her to the