Facts:

The case involves Lino Alejandro y Pimentel as the accused-appellant and the People of the Philippines as the plaintiff-appellee. The events leading to this case began when Pimentel was charged with two counts of rape against a 12-year-old minor, referred to as AAA. The incidents occurred in Cauayan City, Isabela, where AAA testified that Pimentel had followed her, forcibly brought her to a secluded area behind a school, and sexually assaulted her. This first incident was reported to have happened when Pimentel removed AAA's clothing and raped her. The second incident occurred two months later when Pimentel entered AAA's house through a window, undressed both himself and AAA, and again raped her, threatening her life if she disclosed the assaults. Following these events, AAA confided in her mother, BBB, who took her to the Municipal Health Office for examination. Dr. CCC, who conducted the examination, found physical evidence of sexual intercourse, including laceratio...

Facts:

1. Charges and Plea:

   • Accused-appellant Lino Alejandro y Pimentel was charged with two counts of rape under Article 266-A, paragraph 1(a) of the Revised Penal Code, in relation to Republic Act No. 8369 (Family Courts Act of 1997). The victim, AAA, was a 12-year-old minor.
   • Upon arraignment, accused-appellant pleaded not guilty, and the case proceeded to trial.

2. Testimony of AAA:

   • AAA testified that accused-appellant followed her, grabbed her, and brought her to the back of a school, where he removed her clothes, laid on top of her, and inserted his penis into her vagina.
   • Two months later, accused-appellant entered AAA's house through a window, undressed her, and again inserted his penis into her vagina. On both occasions, he threatened to kill her if she told anyone.
   • AAA eventually reported the incidents to her mother, BBB, who brought her to the Municipal Health Office for examination.

3. Medical Findings:

   • Dr. CCC, who examined AAA, found deep, healed, old, and superficial lacerations in AAA's hymen, concluding that these indicated positive sexual intercourse.

4. Defense's Decision:

   • Accused-appellant, through his counsel, decided not to present any evidence for the defense and submitted the case for decision.

5. Initial RTC Decision and Recall:

   • On July 26, 2011, the RTC initially acquitted accused-appellant. However, on the same day, the RTC recalled the decision after realizing that AAA had testified during the trial, but her testimony was mistakenly excluded from the records due to a mix-up with another case.
   • The RTC issued a new decision convicting accused-appellant of two counts of rape, sentencing him to reclusion perpetua for each count and ordering him to pay damages.

6. Appeal to the CA:

   • Accused-appellant appealed to the Court of Appeals (CA), arguing that the RTC erred in recalling its acquittal and that the prosecution failed to prove his guilt beyond reasonable doubt.
   • The CA affirmed the conviction but modified the damages awarded.

7. Appeal to the Supreme Court:

   • Accused-appellant filed a petition for review, arguing that the recall of the acquittal violated his right against double jeopardy and that AAA's testimony was incredible.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Finality of Acquittal:

   • A judgment of acquittal is immediately final and unappealable upon its promulgation. It cannot be recalled, modified, or withdrawn without violating the accused's right against double jeopardy.
   • The RTC's recall of its acquittal, even if based on a mistake, was improper and unconstitutional.

2. Double Jeopardy:

   • For double jeopardy to attach, the following elements must concur:
     • A valid information sufficient to sustain a conviction.
     • A court of competent jurisdiction.
     • The accused has been arraigned and pleaded.
     • The accused was convicted, acquitted, or the case was dismissed without his express consent.
   • All these elements were present in this case, and the recall of the acquittal placed accused-appellant in double jeopardy.

3. Exceptions to Double Jeopardy:

   • The rule on double jeopardy has exceptions, such as deprivation of due process or grave abuse of discretion. However, these exceptions did not apply in this case because the prosecution was able to present its case, and there was no mistrial or grave abuse of discretion.

4. Proper Remedy for Erroneous Acquittal:

   • If the prosecution believes that an acquittal was erroneous, the proper remedy is to file a petition for certiorari under Rule 65 of the Rules of Court, not a mere manifestation.
   • In this case, the RTC's recall of the acquittal based on a prosecutor's manifestation was improper and violated accused-appellant's rights.

5. Credibility of AAA's Testimony:

   • While the Court did not delve deeply into the credibility of AAA's testimony, it emphasized that the procedural error in recalling the acquittal was sufficient to warrant the reversal of the conviction.

The Supreme Court emphasized the importance of the finality of acquittals and the constitutional protection against double jeopardy. The RTC's attempt to rectify its error by recalling the acquittal was a violation of accused-appellant's rights, and the Court upheld the principle that a judgment of acquittal, once final, cannot be altered or withdrawn.