Case Digest (G.R. No. 139181)
Facts:
The case involves the appellant, Jimmy Aquino y Viola, who was convicted of statutory rape by the Regional Trial Court of Malolos, Bulacan, Branch 21, on June 7, 1999. The incident occurred on May 24, 1996, in San Miguel, Bulacan, where Jimmy, armed with a knife, allegedly raped AAA, an 11-year-old girl. The Information filed against him stated that he had carnal knowledge of AAA against her will, using force and intimidation. During the trial, AAA testified that she was called by Jimmy to buy cooking oil and, upon returning, was coerced into removing her clothing at knifepoint. The assault lasted approximately two hours until interrupted by the voice of Jimmy's brother-in-law. After the incident, AAA reported the rape to her grandmother and subsequently to her mother, Lolita Viola de la Cruz, who is also Jimmy's first cousin. Despite initial reluctance from local authorities to act on the complaint, the case was eventually filed in the Municipal Trial Court of San Mi...
Case Digest (G.R. No. 139181)
Facts:
Background of the Case
- The case involves appellant Jimmy Aquino, who was convicted of statutory rape by the Regional Trial Court of Malolos, Bulacan, and sentenced to death. The crime allegedly occurred on 24 May 1996, in San Miguel, Bulacan, where Jimmy, armed with a bladed weapon, was accused of raping AAA, an 11-year-old girl.
Prosecution's Version
- AAA, the victim, testified that on 24 May 1996, Jimmy asked her to buy cooking oil. Upon her return, he ordered her to remove her clothes at knifepoint and proceeded to rape her for two hours. AAA reported the incident to her grandmother and later to her mother, Lolita, who filed a complaint with the barangay. However, no immediate action was taken due to Jimmy's connections in the barangay.
Defense's Version
- Jimmy denied the rape allegations. He claimed that he only asked AAA to undress out of curiosity, as he had heard rumors about her private organ. He stated that children were present in the house during the incident, and no rape occurred. Witnesses, including Antonio Clemente and Rolando Viola, corroborated Jimmy's account, stating that AAA was seen with her shorts down but no rape took place.
Trial Court's Decision
- The trial court found AAA's testimony credible and convicted Jimmy of statutory rape, imposing the death penalty due to the use of a deadly weapon. The court also ordered Jimmy to pay indemnity and moral damages to AAA.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
Credibility of Witnesses: The Supreme Court emphasized that while the trial court's findings on witness credibility are generally respected, appellate courts may reverse such findings if there are overlooked facts or circumstances that could affect the case's outcome. In this case, the Court found inconsistencies in AAA's testimony, particularly regarding the duration of the alleged rape and the presence of witnesses during the incident.
Reasonable Doubt: The Court ruled that the prosecution's evidence did not meet the standard of moral certainty required for a rape conviction. The presence of children and other witnesses during the alleged incident, as well as the delay in filing the rape complaint, cast doubt on the prosecution's case.
Acts of Lasciviousness: Although the Court acquitted Jimmy of rape, it found that his act of ordering AAA to undress constituted acts of lasciviousness. This act, committed against a minor, was deemed lewd and punishable under Article 336 of the Revised Penal Code.
Penalty: The Court imposed an indeterminate sentence for acts of lasciviousness, considering the absence of aggravating or mitigating circumstances.
Conclusion:
- The Supreme Court acquitted Jimmy Aquino of statutory rape but convicted him of acts of lasciviousness. The decision underscores the importance of scrutinizing evidence in rape cases and ensuring that convictions are based on proof beyond reasonable doubt.