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Valenton, Francis Angelo T.

Criminal Law 2


People vs. Echegaray (G.R. No. 117472)

Facts: The plaintiff-appellee is the People of the Philippines. The accused-appellant is Leo
Echegaray. In the case at bar, the complainant is Rodessa Echegaray, the ten-year old daughter of
the herein accused. In April 1994, while everyone of the household was out but the accused and
complainant. The complainant allege that the accused approached Rodessa and suddenly dragged
her inside the room and hade sex with her. It was proven in the medical report that the vagina of
the complainant was in non-virgin state. The accused contend that the rape complaint was
motivated by complainant’s grandmother so that she could own a certain parcel of land. The
defense also presented witnesses, stating the ill-morality of the 10-year old complainant.
However the trial court sill found the herein accused guilty for the crime of rape.

Issue: Is the appellant guilty of rape.

Held: The Supreme Court said that the appellant is guilty of qualified rape. They evidence
presented by the prosecution was appreciated by the trial court and the Supreme Court to hold
the accused guilty of rape committed allegedly to the complainant. Even if the accused said that
such vagina of the complainant be small enough for his organ, the medico legal provided
sufficient evidence to hold conviction. The Supreme Court also said that the death penalty is