Case Digest (G.R. No. 232455)
Facts:
In People of the Philippines v. Teodoro Ansano y Calleja (G.R. No. 232455, December 2, 2020), Ansano was charged with the April 6, 2005 rape of minor AAA (aged 13) in XXX, ZZZ. According to the Information, he threatened AAA with a bolo, dragged her to a secluded area, and forcibly had vaginal and oral sexual intercourse, causing hymenal lacerations confirmed by a medico-legal examination on April 7, 2005. AAA reported the incident to her parents that night and to the police the following day. She first saw Ansano on March 19, 2006, during a drinking spree at her home and later identified him from a single photograph at the municipal hall. Ansano pleaded alibi and denial, testifying that on April 6, 2005, he was at Villa Pokan with friends from 4:00 to 5:00 p.m., then went home and slept. The Regional Trial Court (Branch 26, YYY, ZZZ) convicted him of rape on November 16, 2015, sentencing him to rCase Digest (G.R. No. 232455)
Facts:
- Parties and Procedural History
- The People of the Philippines filed an Information on April 6, 2005 against Teodoro Ansano y Calleja for rape of minor AAA (born September 14, 1991; age 13 at incident), armed with a bolo, by force and intimidation.
- RTC of YYY, ZZZ, Branch 26 rendered judgment on November 16, 2015 finding Ansano guilty beyond reasonable doubt and sentencing him to reclusion perpetua plus damages.
- On February 20, 2017, the CA in CA-G.R. CR-HC No. 08223 affirmed with modifications (increased damages), prompting Ansano’s appeal to the Supreme Court.
- Prosecution Evidence
- AAA’s testimony: on April 6, 2005 at about 5:00 PM near the river in [XXX], Ansano, carrying a bolo and wearing farm clothes, threatened her, led her to a secluded bamboo area, forced her to perform oral sex, then committed vaginal rape twice, and warned her not to tell anyone.
- Identification: she first “recognized” Ansano during a drinking spree with her father on March 19, 2006, noting a scar, “butil-butil” on face, moustache, and slanted eyes; she later confirmed his identity via a single photograph shown at the municipal hall.
- Medico-legal report by Dr. Maria Cheryl Obcemea (exam on April 7, 2005) indicated multiple fresh lacerations of the hymen at 7 and 5 o’clock positions, with minimal bleeding.
- Defense Evidence
- Ansano’s denial and alibi: claimed he was at Villa Pokan swimming with friends on April 6, 2005 at around 5:00 PM, went home thereafter, and slept until the next morning; asserted he did not know AAA.
- No scar on accused’s face: defense counsel and presiding judge verified in open court during testimony that Ansano bore no facial scar.
Issues:
- Did the RTC and CA err in convicting Ansano of rape?
- Was the victim’s identification of Ansano as the perpetrator proven beyond reasonable doubt?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)