People vs. Sarcia CASE DIGEST
People vs. Sarcia CASE DIGEST
People vs. Sarcia CASE DIGEST
Sarcia
G.R. No. 169641 September 10, 2009
Facts:
This case involves the review of a decision by the Court of Appeals (CA) affirming the conviction
of Richard O. Sarcia for the crime of rape. The crime was allegedly committed against a five-
year-old girl named AAA in 1996. The father of AAA initially filed a complaint for acts of
lasciviousness against Sarcia, but it was later upgraded to rape by the Office of the Provincial
Prosecutor. Sarcia pleaded not guilty during his arraignment and a trial on the merits ensued.
The prosecution presented testimonies from AAA, her minor cousin, her father, and Dr. Joana
Manatlao, the Municipal Health Officer. The defense presented Sarcia himself and a court clerk.
The trial court found Sarcia guilty of rape and sentenced him to Reclusion Perpetua, as well as
ordered him to pay civil indemnity, moral damages, and the cost of the suit. The CA affirmed the
conviction but modified the penalties imposed by the trial court, imposing the death penalty
instead of Reclusion Perpetua and increasing the amount of civil indemnity and awarding
exemplary damages.
Issue:
The main issues raised by Sarcia in his appeal were the credibility of the prosecution witnesses,
the alleged inconsistencies in their testimonies, the delay in filing the case, and the lack of proof
of force, threats, or intimidation. He also questioned the interpretation of the medical certificate,
which stated that there was no showing of any scar or wound.
Ruling:
The CA, in its decision, affirmed the judgment of conviction and imposed the death penalty on
Sarcia. The court found that the inconsistencies in the testimonies of the prosecution witnesses
were minor and did not affect the veracity of their testimonies. The court also held that the delay
in filing the case was not a ground for acquittal, and the prosecution was able to prove the
elements of rape beyond reasonable doubt. The court further explained that the absence of
scars or wounds does not negate the commission of rape, as the hymen can be perforated by
various means.
Ratio:
The court found the accused guilty based on the testimonies of the victim and other witnesses,
despite minor inconsistencies. The court also rejected the defense's arguments regarding the
delay in filing the case and the interpretation of the medical certificate. The CA affirmed the
conviction and imposed the death penalty.