G.R. No. 223099 - People vs. Alejandro y Pimentel

Accused-appellant Lino Alejandro y Pimentel was charged with two counts of rape under Article 266-A(1)(a) of the Revised Penal Code, in relation to Republic Act No. 8369, involving a 12-year-old minor, AAA.
The case was docketed as Criminal Case Nos. Br. 20-6096 & 20-6097 before the Regional Trial Court (RTC) of Cauayan City, Isabela, Branch 20.

Upon arraignment, the accused pleaded not guilty. During trial, AAA testified to two separate acts of rape:

In a school yard, the accused followed, grabbed her, removed her clothes, lay on top of her, and inserted his penis into her vagina.
Two months later, he entered her house through a window at night, undressed both, and again penetrated her. In both instances, he threatened to kill her if she spoke.

AAA’s mother brought her for medico-legal examination; Dr. CCC found deep, healed and superficial hymenal lacerations, indicating positive sexual intercourse.
The defense rested without presenting evidence. On July 26, 2011, the RTC promulgated a decision acquitting the accused, but immediately recalled and set aside that decision upon the prosecutor’s manifestation that AAA did testify (the testimony was mistakenly placed in another case record).

The RTC denied the accused’s motion for reconsideration, holding that the acquittal was invalid because it contravened the facts and the law.
In the recalled Joint Decision dated July 26, 2011, the RTC found the accused guilty beyond reasonable doubt of two counts of simple rape (Article 266-A, par. 1(d), RPC as amended by RA 8353) and sentenced him to reclusion perpetua per count, plus damages.

The accused appealed, contesting the recall of the acquittal and the sufficiency of evidence. The Office of the Solicitor General (OSG) defended the recall as a correction of oversight, not a second trial.
On February 17, 2015, the Court of Appeals (CA) dismissed the appeal, upholding the RTC’s recall as justified due to incomplete records, affirmed the conviction, and modified damages to include 6% interest per annum from finality.

The accused elevated the case to the Supreme Court, invoking the finality of acquittal and protection against double jeopardy, and challenging AAA’s credibility.
The OSG maintained that recalling the acquittal did not violate double jeopardy because no new evidence was presented and no appeal was taken of the acquittal.
The Supreme Court granted the petition, reversed the CA and RTC decisions, and acquitted and ordered the release of the accused-appellant.

Whether the RTC had the power to recall and set aside its judgment of acquittal.
Whether the recall and subsequent conviction violated the accused-appellant’s constitutional right against double jeopardy.
Whether the evidence, particularly the testimony of the minor victim, was sufficient and credible to support conviction.