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Case Digest - G.R. No. 196342 - People vs. Caoili

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44 views2 pages

Case Digest - G.R. No. 196342 - People vs. Caoili

Uploaded by

Vanesa Lhea
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© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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12/17/24, 5:50 PM Case Digest: G.R. No. 196342 - People vs.

Caoili

Title
People vs. Caoili

Case Decision Date


G.R. No. 196342 Aug 8, 2017

Conviction for lascivious conduct against a child upheld, clarifying that rape by
sexual assault is distinct from rape by sexual intercourse.

Jur.ph - Case Digest (G.R. No. 196342)


Comprehensive

Facts:
The case involves two consolidated petitions for review, G.R. No. 196342 and G.R. No.
196848.
The accused, Noel Go Caoili, also known as "Boy Tagalog," was charged with sexually
assaulting his daughter, referred to as AAA.
On October 23, 2005, AAA, then 15 years old, testified that her father sexually
molested her at their home in Barangay JJJ, KKK, LLL, Philippines.
An Information was filed on June 22, 2006, by First Assistant Provincial Prosecutor
Raul O. Nasayao, charging Caoili with rape through sexual intercourse, alleging the
use of force, threat, and intimidation.
The Regional Trial Court (RTC) of Surigao City, Branch 30, found Caoili guilty of rape
by sexual assault on June 17, 2008, sentencing him to imprisonment and ordering
damages to AAA.
Caoili appealed to the Court of Appeals (CA), which on July 22, 2010, set aside the
RTC's ruling but found him guilty of rape by sexual assault, remanding the case for
further proceedings.
Both parties filed separate petitions for review before the Supreme Court, which
consolidated the cases.

Issue:
(Unlock)

Ruling:
The Supreme Court ruled that the petitions lack merit.

https://jur.ph/jurisprudence/digest/people-v-caoili 1/2
12/17/24, 5:50 PM Case Digest: G.R. No. 196342 - People vs. Caoili

It affirmed the CA's decision to set aside the RTC's ruling and remand the case for
further proceedings.
The Court held that while the prosecution established the crime of rape by sexual
assault, Caoili could not be convicted based on the Information ch...(Unlock)

Ratio:
The Supreme Court emphasized the significant distinction between rape by sexual
intercourse and rape by sexual assault.
Rape by sexual intercourse requires proof of carnal knowledge, while rape by sexual
assault involves acts of sexual assault without penetration.
The variance doctrine, which allows for conviction of a lesser included offense, does
not apply here as the two offenses are not necessarily included within each other.
The Court reiterated the fundamental right of an accused to be informed of the n...

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https://jur.ph/jurisprudence/digest/people-v-caoili 2/2

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