Case Summary (G.R. No. 151258)
Applicable Law
The case involves the interpretation and application of Republic Act No. 7610 and the Revised Penal Code (RPC), specifically Article 336, concerning acts of lasciviousness.
Facts of the Case
An Information was filed against XXX, alleging that he committed lascivious acts against AAA, who was eight years old at the time. The prosecution's case presented that XXX, the common-law husband of AAA's mother, initiated inappropriate contact with AAA, including touching her breasts and vagina. This abuse reportedly occurred repeatedly over a span of several years, witnessed by AAA's mother, who failed to intervene. When AAA eventually moved in with her sister BBB, she disclosed the abuse, prompting BBB to file charges.
Defense's Argument
The defense, presented solely by XXX, relied on alibi and denial. He claimed he was working in Cavite during the relevant period and never lived with AAA's family. His defense suggested that any allegations made by AAA were motivated by familial disputes, citing that he had never met AAA directly.
Ruling of the RTC
The Regional Trial Court convicted XXX of violating Section 5(b) of Republic Act No. 7610, emphasizing the credibility of AAA's testimony, which was found to be consistent and straightforward. The RTC also noted that AAA's delayed reporting of the incidents did not detract from her credibility as a victim. The RTC sentenced XXX to an indeterminate prison term and required him to pay civil indemnity and damages.
Ruling of the CA
The Court of Appeals affirmed the RTC's ruling, reiterating the sufficiency of AAA's evidence to establish all elements of the crime. The CA dismissed XXX’s defenses as weak when measured against the victim's credible testimony.
Legal Issues Raised on Appeal
XXX appealed on the ground that the lower courts erred in convicting him due to insufficient proof of the victim’s age, which is critical under the doctrines established in previous jurisprudence.
Court's Ruling on Conviction
The Supreme Court modified the conviction, reducing the charge from "Acts of Lasciviousness under the RPC in relation to R.A. 7610" to "Acts of Lasciviousness under the RPC." The prosecution's failure to present sufficient evidence of AAA's age, particularly the absence of her birth certificate and reliance on an unauthenticated baptismal certificate, led the court to conclude that R.A. 7610 could not be applied.
Elements of the Crime
The elements of acts of lasciviousness were found sufficiently proven despite the victim's age not being verified in accordance with the le
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Case Overview
- The case involves a Petition for Review on Certiorari filed by the petitioner XXX challenging the Decision dated July 26, 2018, and Resolution dated November 6, 2018, of the Court of Appeals in CA-G.R. CR No. 40229.
- The Court of Appeals affirmed the Decision dated July 12, 2016, of the Branch 36, Regional Trial Court of Calamba City, Laguna, which found XXX guilty beyond reasonable doubt of violating Section 5(b) of Republic Act No. 7610 (R.A. 7610).
Factual Background
- An Information was filed against XXX for committing lascivious acts against AAA, an eight-year-old girl, in 2005 at their residence in Laguna.
- The allegations included using force, intimidation, and coercion to touch AAA's breasts and vagina against her will.
- During the trial, AAA testified about the incidents, detailing repeated abuse by XXX, including instances witnessed by her mother, who did not intervene.
- AAA's sister, BBB, corroborated her testimony, indicating that AAA had been abused continuously until she left home in 2010.
- The prosecution also presented a baptismal certificate and a social case study report that concluded AAA was a victim of sexual abuse.
Defense's Version
- XXX interposed a defense of denial and alibi, claiming he was not living with AAA and her family in 2005, and was instead working in Cavite.
- He argued that he had never met AAA and sugges