Cited Laws
TL;DR — Ruling
The appeal is without merit.
Accordingly, the RTC sentenced accused-appellant to suffer the penalty of reclusion perpetua and ordered him to pay AAA the following amounts: (a) P50,000.00 as civil indemnity; (b) P50,000.00 as moral damages; and (c) P30,000.00 as exemplary damages. It also imposed interest at the legal rate of 6% per annum on the monetary award from the date of finality of the judgment until fully paid. [20] Accused-appellant thereafter appealed before the CA. The CA Ruling In its Decision [21] dated August 14, 2017, the CA affirmed the RTC Decision with modification in that it increased the amounts of civil indemnity, moral damages, and exemplary damages to P75,000.00 each in view of recent jurisprudence. [22] The CA ruled that AAA had given a clear, positive, and straightforward account of the rape incident. [23] It thus concluded that: In the present case, it has been sufficiently established that the accused-appellant employed force in order to succeed in his lustful act. AAA testified that as soon as she was laid down on the floor, accused-appellant went on top of her, and pinned her hands to her chest as he removed her undergarments and inserted his penis into her vagina. The medico-legal report also revealed the presence of shallow healed lacerations at 3 and 9 o'clock positions and deep healed laceration at 6 o'clock position. Furthermore, the findings stated that there is clear evidence of previous blunt force or penetrating trauma. Clearly, the evidence shows that the accused-appellant employed force in order to attain his lustful act. And, when the consistent and forthright testimony of a rape victim is consistent with medical findings, there is sufficient basis to warrant a conclusion that the essential requisites of carnal knowledge have been established. [24] Thus, the instant appeal. The Issues Accused-appellant raises the following issues for the Court's resolution: first , whether the lower courts committed an error in giving full credence to AAA's "doubtful" and "improbable" testimony; [25] and second , whether the prosecution was able to prove the essential element of force or intimidation beyond reasonable doubt. [26] The Court's Ruling The appeal is without merit. In cases where the issue rests upon the credibility of witnesses, the settled rule is that "appellate courts accord the highest respect to the assessment made by the trial court because of the trial judge's unique opportunity to observe the witnesses firsthand and to note their demeanor, conduct and attitude under grueling examination." [27] Thus, the Court explained in People v. Espino, Jr. [28] that the findings of the trial court will not be overturned unless it is clearly shown that it had overlooked, misunderstood , or misapplied some facts or circumstances of weight or substance that could have altered the outcome of the case. [29] "The rule finds an even more stringent application where said findings are sustained by the [CA]." [30] In this case, the Court finds no cogent
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