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PEOPLE v. CARLOS ALHAMBRA Y MASING

FACTS:

The case involves Carlos Alhambra y Masing's appeal from the decision of the Court of Appeals (CA) affirming the decision of the Regional Trial Court (RTC) finding him guilty of rape and sexual abuse. Alhambra's own daughter, AAA, accused him of raping her on two separate occasions and sexually abusing her on another occasion.

According to AAA's testimony, her father entered her room, removed her undergarments, and kissed her on various parts of her body before raping her. She also alleged that her father sexually abused her by kissing and touching her inappropriately. AAA reported the incidents to the police, leading to Alhambra's arrest. However, Alhambra denied the allegations and claimed that AAA fabricated them.

The RTC acquitted Alhambra of the rape charge but found him guilty of rape in another case and sexual abuse under R.A. No. 7610. The RTC relied on AAA's testimony, which it deemed to be simple, direct, and spontaneous. Alhambra appealed the RTC decision, arguing that AAA was not a credible witness and that the charges against him were not proven beyond reasonable doubt.

The CA affirmed the RTC decision, stating that Alhambra's acquittal in one case did not negate his criminal liability in the other case. The CA also held that AAA's delayed reporting of the incidents did not diminish her credibility as a witness. Alhambra and the Office of the Solicitor General both chose not to file additional briefs.

ISSUES:

  1. Whether the prosecution was able to establish beyond reasonable doubt all the elements of rape under Article 266-A of the Revised Penal Code.

  2. Whether Alhambra is liable for sexual abuse under Section 5(b), Article III of R.A. No. 7610.

  3. Whether the penalties imposed on Alhambra are appropriate and in accordance with the law.

  4. Whether accused-appellant should be sentenced to suffer the penalty of reclusion perpetua, without eligibility for parole.

  5. Whether accused-appellant should be ordered to pay interest on monetary awards for damages at the rate of six percent (6%) per annum.

RULING:

  1. Yes, the prosecution was able to establish beyond reasonable doubt all the elements of rape. The court found that AAA's testimony, which was straightforward and worthy of credence, established that Alhambra succeeded in having carnal knowledge with her through the use of force and/or intimidation. The court also ruled that AAA's delay in filing a complaint against Alhambra does not discredit her testimony, as delay in reporting an incident of rape does not create any doubt over the credibility of the complainant. Minor inconsistencies in AAA's testimony also do not affect her credibility, as they only pertain to minor details and collateral matters. The court also noted that it is highly unlikely for AAA to fabricate a story of rape given her young age and the trauma associated with such an experience. Thus, the court upheld Alhambra's conviction for rape.

  2. Alhambra is liable for sexual abuse under Section 5(b), Article III of R.A. No. 7610. The prosecution was able to establish Alhambra's criminal liability through the testimony of the victim, AAA. Alhambra's defense of denial and alibi is deemed weak and self-serving. The law covers not only situations where a child is abused for profit but also when a child engages in lascivious conduct through coercion or influence. Alhambra used his moral ascendancy and influence over AAA to consummate his lascivious design.

  3. The penalties imposed on Alhambra are appropriate and in accordance with the law. In Criminal Case No. 220-05, the penalty of reclusion perpetua without eligibility for parole is imposed due to the aggravating circumstance of being the parent of the victim. The award of moral damages, civil indemnity, and exemplary damages is affirmed. In Criminal Case No. 347-04, the penalty of reclusion perpetua without eligibility for parole is imposed due to the aggravating circumstance of relationship. The accessory penalties of fine, civil indemnity, moral damages, and exemplary damages are also affirmed. Interest on all monetary awards for damages is imposed at the rate of six percent (6%) per annum from the date of finality of the decision until fully paid.

  4. Accused-appellant Carlos Alhambra y Masing is sentenced to suffer the penalty of reclusion perpetua, without eligibility for parole.

  5. Accused-appellant Carlos Alhambra y Masing is ordered to pay interest on all monetary awards for damages at the rate of six percent (6%) per annum from the date of finality of this Resolution until fully satisfied.

PRINCIPLES:

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

  • Delay in reporting an incident of rape does not create doubt over the credibility of the complainant unless it is unreasonable or unexplained.

  • Minor inconsistencies in the testimony of a witness do not affect their credibility as long as the central fact of the crime is coherent and believable.

  • It is highly unlikely for a rape victim, especially a young and immature one, to fabricate a story of rape given the trauma associated with such an experience.

  • Denial and alibi are inherently weak defenses.

  • Child abuse under Section 5(b), Article III of R.A. No. 7610 encompasses situations where a child engages in lascivious conduct through coercion or influence, not just situations of exploitation for profit.

  • The penalty for sexual abuse under Section 5(b) of R.A. No. 7610 is reclusion temporal in its medium period to reclusion perpetua, and shall be applied in its maximum period if there is an aggravating circumstance and no mitigating circumstance.

  • The penalty of reclusion perpetua without eligibility for parole shall be imposed when the victim is under eighteen (18) years of age and the offender is a parent.

  • Interest at the rate of six percent (6%) per annum shall be imposed on all monetary awards for damages from the date of finality of the decision until fully paid.

  • Reclusion perpetua is a penalty that may be imposed by the court on a person found guilty of a certain offense.

  • The imposition of reclusion perpetua means that the convicted person will spend the rest of their natural life behind bars.

  • The court may order the payment of interest on monetary awards for damages, which will accrue at a specified rate per annum until the amount is fully satisfied.