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PEOPLE v. ROLANDO BARAGA Y ARCILLA

FACTS:

Accused-appellant Rolando Baraga was charged with three counts of acts of lasciviousness and two counts of rape committed against his daughter, AAA, who was then a minor. The prosecution alleged that the initial lascivious conduct occurred on April 2, 2007, when Baraga touched AAA's vagina. On August 8, 2007, Baraga approached AAA while she was sleeping, held her thigh, touched her vagina, and eventually raped her. On August 15, 2007, Baraga again went on top of AAA while she was sleeping and raped her. On August 19, 2007, Baraga touched AAA's vagina once more. AAA reported these incidents to her uncle, who then forbade her to return home. The matter was reported to the police and AAA underwent a medical examination that revealed evidence of trauma. Baraga denied the allegations and claimed that AAA was influenced by a certain Veronica Cruz to fabricate the charges against him. The Regional Trial Court (RTC) found Baraga guilty of acts of lasciviousness and rape, except for one count of acts of lasciviousness. The RTC imposed penalties and awarded damages. The Court of Appeals (CA) affirmed the RTC's decision with modifications on the penalties. Baraga appealed to the Supreme Court, arguing that the prosecution failed to prove his guilt.

ISSUES:

  1. Whether the trial court erred in convicting the accused-appellant based solely on the testimony of the victim.

  2. Whether the prosecution was able to prove the guilt of the accused beyond reasonable doubt.

RULING:

  1. The appeal is without merit. The Supreme Court affirmed the decision of the trial court, finding the accused-appellant guilty beyond reasonable doubt of two counts of acts of lasciviousness and two counts of rape. The Court held that the factual findings of the trial court are generally accorded great weight on appeal, especially when supported by substantial evidence. The Court also emphasized that it will only re-evaluate the factual findings of the trial court in exceptional circumstances, such as when material and relevant matters are overlooked. In this case, the Court found no reason to depart from this rule.

PRINCIPLES:

  • Factual findings of the trial court are generally given great weight and respect on appeal, especially when supported by substantial evidence.

  • The Supreme Court will only re-evaluate the factual findings of the trial court in exceptional circumstances, such as when material and relevant matters are overlooked.