Case Digest (G.R. No. 221538)
Facts:
In G.R. No. 261422, decided on November 13, 2023 under the 1987 Constitution, AAA261422, a thirteen‐year‐old minor represented by her aunt YYY261422, filed three Informations against her mother’s common‐law partner, XXX261422, in the Regional Trial Court (RTC) of xxxxxxxxxxxxxxxxx. He was charged with two counts of rape under Article 266-A of the Revised Penal Code (as amended by RA 8353) and one count of acts of lasciviousness in relation to RA 7610 (Special Protection of Children). The three complaints described separate incidents occurring on December 25, 2017, and the second and third weeks of January 2018, in which AAA261422 alleged that XXX261422 forcibly covered her mouth, fondled and kissed her breasts, unzipped her shorts, inserted his finger into her vagina, and, on one occasion, pressed his penis against her thigh. At trial, the prosecution presented AAA261422, YYY261422 and Dr. Ava O. Liwanag, whose medico‐legal examination confirmed hymenal laceration consistent witCase Digest (G.R. No. 221538)
Facts:
- Parties and Procedural History
- AAA261422, a 13-year-old minor represented by her aunt YYY261422, filed a petition for certiorari before the Court of Appeals.
- Respondent XXX261422, common-law spouse of AAA261422’s mother, was accused of sexually abusing AAA261422 in three separate Informations.
- Criminal Charges and Trial
- Criminal Case No. 21-3964 and No. 21-3966: two counts of rape under Article 266-A, Revised Penal Code (as amended by RA 8353).
- Criminal Case No. 21-3965: one count of acts of lasciviousness under RA 7610.
- Prosecution presented AAA261422, YYY261422, and Dr. Ava O. Liwanag, who testified to three incidents of digital and manual sexual abuse and breast fondling; medico-legal exam showed hymenal laceration.
- Defense presented XXX261422, CCC261422 (mother), and a neighbor, who denied the incidents and suggested a family‐driven conspiracy.
- Lower Court Decisions and Appeals
- RTC Branch XXX (June 18, 2019) acquitted XXX261422 for lack of credible evidence, citing possible concoction and the small room’s noise-bearing. Imposed civil damages of ₱150,000.00.
- RTC denied reconsideration on procedural grounds (July 26, 2019).
- Court of Appeals dismissed AAA261422’s Rule 65 petition (June 25, 2020) and denied reconsideration (December 22, 2020) for lack of Office of the Solicitor General (OSG) conformity.
Issues:
- Standing and OSG Conformity
- May a private complainant file a petition for certiorari under Rule 65 to assail an acquittal without securing the OSG’s conformity?
- Substantive Merits
- Did the RTC commit grave abuse of discretion amounting to lack of jurisdiction or denial of due process in acquitting XXX261422?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)