Facts:

This case involves the petitioner AAA261422, a minor represented by her guardian YYY261422, against the respondent XXX261422. The events in question took place in the Philippines, specifically in the xxxx region, with incidents reported from December 25, 2017, and up until January 2018. XXX261422 was charged with two counts of rape under Article 266-A of the Revised Penal Code, as amended by Republic Act No. 8353, and one count of acts of lasciviousness in violation of Republic Act No. 7610. During the trial, the prosecution presented various witnesses, including AAA261422 herself, her aunt YYY261422, and Dr. Ava O. Liwanag, a health officer who examined the victim.

AAA261422 testified that she was assaulted by XXX261422—who was the common-law spouse of her mother—while she was asleep in her room. The incidents included being forcibly touched and having her breasts assaulted. Despite the evidence presented, the Regional Trial Court acquitted XXX261422 on the basis of reasonable

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Facts:

Background of the Case

• AAA261422, a minor represented by YYY261422, filed a petition for certiorari challenging the Court of Appeals’ dismissal of her petition, which questioned the acquittal of XXX261422 in connection with criminal charges.
• The case involves serious allegations of rape and acts of lasciviousness committed by XXX261422 against AAA261422, a 13-year-old minor, with the abuse allegedly occurring on three separate occasions.
• The incidents occurred on December 25, 2017, and during the second and third weeks of January 2018. The acts included forcibly touching and manipulating the victim’s breasts, forcibly unzipping her clothing, and inserting his finger into her vagina; on one occasion, the accused also used his penis to touch her thigh.

Chronology of Proceedings

• During the criminal trial, XXX261422 was charged with two counts of rape under Article 266-A of the Revised Penal Code (as amended by Republic Act No. 8353) and one count of acts of lasciviousness in relation to Republic Act No. 7610.
• The trial court, issuing a joint decision, acquitted the accused on grounds of reasonable doubt but simultaneously held him civilly liable by ordering the payment of damages to AAA261422.
• AAA261422 subsequently filed a petition for certiorari under Rule 65 before the Court of Appeals, not challenging the acquittal per se but raising issues of jurisdiction and grave abuse of discretion amounting to a denial of due process.
• The Court of Appeals dismissed the petition on procedural grounds – notably on the failure to secure the conformity of the Office of the Solicitor General (OSG) – and later denied her motion for reconsideration.

Evidence and Testimonies

• Prosecution Evidence:
• AAA261422’s detailed and consistent testimony concerning the sexual incidents which explicitly described the sequence of events during each alleged assault.
• Medical evidence provided by Dr. Ava O. Liwanag, including the Medico Legal Certificate showing results such as a lacerated hymen, which was supportive of the victim’s account.
• Corroborative testimony from other witnesses including YYY261422.
• Defense Evidence:
• Testimonies by XXX261422 and other family members, which sought to undermine the credibility of the victim’s narrative by emphasizing the improbability of the assault in a small room where noises could have alerted others.
• Arguments that the victim’s allegations were concocted under the influence of external parties aiming to disrupt the familial relationship.

Procedural and Substantive Controversies

• The trial court’s acquittal decision was heavily criticized for having relied more on the defense’s version than on the evidentiary support provided by the victim, thereby exposing a potential abuse of discretion.
• AAA261422 raised arguments that her petition – though addressing the criminal aspects – should be considered given special and compelling circumstances, emphasizing the state’s duty to protect the rights of children and ensure due process.
• The OSG and the defense contended that only the state, through the OSG, has standing to appeal judgments affecting the criminal aspects of a case, while a private complainant’s appeal is limited to civil issues.

Issue:

Legal Standing and Appellate Authority

• Whether a private complainant, in this case AAA261422, has the legal personality to file a petition for certiorari challenging a trial court’s judgment on criminal matters without the conformity of the OSG.
• Whether the guidelines set forth in recent jurisprudence (e.g., Austria v. AAA and BBB) should be applied prospectively, thereby precluding or permitting her stand-alone appeal on the criminal disposition.

Evaluation of Grave Abuse of Discretion and Denial of Due Process

• Whether the trial court committed grave abuse of discretion by acquitting XXX261422 on a basis of mere conjecture and unsubstantiated surmises, rather than a careful and independent evaluation of the evidence.
• Whether the trial court’s decision adversely affected the constitutionally protected right to due process of both the People and the private complainant, AAA261422.

Applicability of Jurisprudential Exceptions

• Whether, given the special circumstances and the procedural history predating the current guidelines, AAA261422’s petition should be entertained despite the lack of the OSG’s involvement.
• Whether the recognition of the victim’s detailed testimony and the corroborative medical evidence justify the reconsideration of the trial court’s acquittal and the dismissal of the petition by the appellate court.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)