Facts:
Maria Rosilyn Delantar, an 11-year-old girl under the guardianship of Simplicio Delantar, was introduced to Romeo Jalosjos, a member of Congress, by a talent manager with the promise of helping her become an actress. Jalosjos gave her money after their first few meetings. On several occasions at his condominium unit, Jalosjos committed several acts of lasciviousness and later, rape against Delantar. She was instructed by her guardian that as long as there was no penetration, the acts were acceptable.
On December 16, 1996, Jalosjos was charged with two counts of statutory rape and twelve counts of acts of lasciviousness. He was acquitted in six counts of acts of lasciviousness due to reasonable doubt. Upon arraignment, Jalosjos refused to enter a plea, leading the trial court to enter a plea of not guilty on his behalf. The prosecution presented eight main witnesses and documentary evidence, while the defense had twenty-six witnesses and its documentary evidence.
Issues:
1. Whether Jalosjos committed statutory rape against Delantar.
2. Whether Jalosjos committed acts of lasciviousness against Delantar.
3. Whether Jalosjos correctly identified as the perpetrator and not his brother, Dominador Jalosjas.
4. Whether the extensive publicity of the case resulted in a mistrial.
5. Whether Delantar’s age was established as below twelve during the commission of the crimes.
Court’s Decision:
The court upheld Jalosjos’ conviction for two counts of statutory rape, as Delantar was determined to be less than twelve years old at the time of the assault, and penetration was proven. The court affirmed Jalosjos’ conviction for six counts of acts of lasciviousness and modified his sentence to an indeterminate sentence of twelve years and one day to fifteen years, six months, and twenty days of reclusion temporal for each count. Jalosjos was ordered to pay Delantar PHP 50,000 as moral damages for each count of acts of lasciviousness and an additional PHP 50,000 as civil indemnity for each count of statutory rape and acts of lasciviousness. The court found that the media publicity did not result in a mistrial and that Delantar’s identity as an 11-year-old at the time of the crime was established.
Doctrine:
In cases of statutory rape, the age of the victim may be proved by the presentation of her birth certificate, and carnal knowledge of a child below twelve years old is considered statutory rape, regardless of the child’s involvement in prostitution.
Class Notes:
– In statutory rape, carnal knowledge with a minor under twelve is punishable regardless of consent.
– Positive identification of the accused as the perpetrator by the victim is key – consistency and firmness in the victim’s testimony is crucial.
– In cases where the credibility of testimonies is contested, the trial court’s assessment is given weight due to its direct interaction with the witnesses.
– The publicity surrounding a case does not automatically constitute a mistrial if it can be shown that the defendant was given the chance to present his case freely.
– Official records, such as birth and baptismal certificates or hospital records, are admissible as prima facie evidence of the facts therein stated.
Historical Background:
This case underscored the gravity with which the Philippine legal system viewed crimes of sexual abuse, particularly against minors, irrespective of the status of the perpetrator. It highlights the stringent measures and legal principles that have evolved to protect the rights and dignity of young victims of sexual offenses.
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