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JurisprudenceG.R. Nos. 140736-39 -

G.R. Nos. 140736-39 - PEOPLE OF THE PHILIPPINES, VS. CARLOS LILO, ACCUSED-.D E C I S I O N - Supreme Court E-Library

En Banc

Cited Laws

RA 7659RA 712,RA 7659,RA 555,RA 100,RA 811,
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TL;DR — Ruling

WHEREFORE, premises considered, the court, finding the accused, Carlos Lilo, guilty of four (4) counts of rape beyond reasonable doubt, imposes upon him the following penalties: In each of the cases docketed as Crim. Cases Nos. 49824, 49825 and 49826, the penalty of reclusion perpetua with the accessory penalties as provided in Article 42 of the Revised Penal Code; In Crim. Case No.

Decision

Ruling

WHEREFORE, premises considered, the court, finding the accused, Carlos Lilo, guilty of four (4) counts of rape beyond reasonable doubt, imposes upon him the following penalties: In each of the cases docketed as Crim. Cases Nos. 49824, 49825 and 49826, the penalty of reclusion perpetua with the accessory penalties as provided in Article 42 of the Revised Penal Code; In Crim. Case No. 49823 the penalty of death with such accessory penalties as provided in Article 40 of the Revised Penal Code; and To pay private complainant P50,000.00 as moral damages as well as pay the cost. [23] Before this Court, accused-appellant disputes the finding that he is guilty beyond reasonable doubt, [24] and assails the reliance by the trial court on the testimony of AAA who was merely motivated, so he claims, by resentment in filing the complaint due to the fact that he often maltreated her. [25] Accused-appellants submission does not persuade. This Court finds his claim to be a mere afterthought for, during the trial, when asked if he knew of any motive why AAA filed the cases against him, he replied in the negative. [26] Further, this Court has consistently echoed its ruling that parental punishment would not suffice to egg one to falsely charge ones father with rape. [27] Accused-appellant goes on to harp on AAAs inability to recall the exact date when the incident in October 1995 was allegedly committed. [28] Failure to recall the exact date of the crime, however, is not an indication of false testimony, [29] for even discrepancies regarding exact dates of rapes are inconsequential and immaterial and cannot discredit the credibility of the victim as a witness. [30] Accused-appellant goes further to posit that rape could not have been committed in October 1995 in broad daylight, particularly in a farm where there were other people who were supposed to be at work. [31] Judicial notice, however, is taken of the fact, and it can be considered of public knowledge, that the scene of rape is not always or necessarily isolated or secluded, [32] as it can be committed even in places where people congregate, in parks along the roadside, in school premises, in a house where there are other occupants, in the same room where other members of the family are also sleeping, and even in places which to many would appear unlikely and high-risk venues for its commission. [33] Finally, accused-appellant focuses on AAAs behavior after the alleged rape incidents as running counter to human nature. [34] He cites AAAs casually leaving the place where she claims to have been molested in October 1995 and continuing to work in the farm with him as if nothing happened. [35] The behavior or reaction of every person to a certain event cannot, however, be predicted with accuracy, and may be dealt with in any way by the victim whose testimony may be given full credence so long as her credibility is not tainted by any modicum of doubt. [36] The undoubted credibility of the witness in AAA and