Case Digest (G.R. No. 247007)
Facts:
People of the Philippines v. AAA, G.R. No. 247007, March 18, 2021, the Supreme Court First Division, Peralta, C.J., writing for the Court.The accused-appellant AAA was charged by Information dated September 10, 2007 with Rape under Article 266‑A, paragraph 1(d) and paragraph 2 in relation to Article 266‑B of the Revised Penal Code for an alleged sexual attack on BBB, then a minor. At arraignment the Information was read in the Cebu‑Visayan dialect and AAA pleaded not guilty; at pre‑trial the parties stipulated to AAA’s identity and to BBB’s minority.
At the trial level the prosecution presented BBB, her siblings CCC and DDD, and her father EEE. Their testimonies described events on the evening of August 23, 2007: AAA, who frequently slept at the family home, allegedly carried BBB to a nearby banana plantation, removed her pants and underwear, touched and then repeatedly inserted his penis into her vagina while covering her mouth, and afterwards returned home. BBB later reported the assault to her father; her jogging pants and panty were recovered at the plantation. BBB also identified AAA as her assailant, citing illumination from a neighbor’s light and familiarity with his voice. The prosecution presented Medico‑legal Officer Dr. Roslyn Orais, who testified to redness of the fourchette and hymenal lacerations at 6:00 and 9:00 positions, findings she opined were highly suggestive of sexual abuse.
The defense offered the testimony of AAA and witnesses VVV, WWW and XXX (his father). AAA denied the charges, claiming he slept through the night at the house; defense witnesses placed him in the vicinity but could not attest that he remained asleep all night. XXX suggested a possible motive tied to an unrelated grudge between families. The defense objected to the admissibility of Exhibit “C,” an unauthenticated photocopy of BBB’s birth certificate.
On November 18, 2013, the Regional Trial Court (RTC), Branch 1, Butuan City (Judge Eduardo S. Casals), found AAA guilty beyond reasonable doubt of Rape under Article 266‑A, paragraph 1(d) (statutory rape), sentenced him to reclusion perpetua, and awarded P50,000 civil indemnity and P50,000 moral damages. The RTC based conviction chiefly on BBB’s categorical testimony and the medical findings; it rejected AAA’s denial as self‑serving.
AAA appealed to the Court of Appeals (CA). On January 24, 2019 (CA‑G.R. CR‑HC No. 01292‑WN), the CA affirmed the RTC’s conviction but modified the damages to P75,000 each for civi...(Pro-only)
Issues:
- Did the prosecution prove AAA’s guilt beyond reasonable doubt, particularly as to identity and carnal knowledge?
- Was there sufficient proof that the victim BBB was under twelve years of age to sustain a conviction for statutory rape under Art...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)