G.R. No. 181491 - People vs. Arcillas

The case involves the rape of a 13-year-old girl, designated AAA, who is a minor over 12 but under 18 years of age.
The accused, Henry Arcillas, was living in a common-law relationship with the victim’s mother, BBB, despite the information erroneously alleging that he was AAA’s stepfather.
AAA had recently graduated from elementary school and was residing with her mother, her siblings, and the accused in a simple shanty in Brgy. Magsaysay, Municipality of Uson, Masbate.

On the evening of May 12, 2000, around 11:00 o’clock, AAA was asleep in a small one-room shanty when she was suddenly awakened.
AAA felt the presence of Henry Arcillas lying on top of her and noticed that he had removed her short pants and panties, with her experiencing pain as he made push and pull movements.
Responding to her distress, AAA called out to her mother, BBB, who was sleeping in close proximity.

Upon awakening, BBB quickly lit a gas lamp and saw the naked accused beside her daughter.
In her indignation, BBB grabbed an ax and struck Arcillas, who managed to evade the blow and was subsequently driven away.
Following the incident, AAA initially contemplated leaving for her grandmother’s place in Alimango, Cataingan, though BBB later prevented her from traveling that night.
AAA eventually went to her grandmother’s residence about two weeks later, when circumstances allowed.

A complaint for qualified rape was initially lodged by AAA (with the involvement of her step-daughter role, despite the mischaracterization) on May 22, 2000.
On August 29, 2000, the Office of the Provincial Prosecutor of Masbate filed an information charging Arcillas with qualified rape, alleging that he was AAA’s stepfather.
The prosecution introduced testimonies of several witnesses including AAA, BBB, AAA’s siblings, and law enforcement officers, as well as medical evidence from Dr. Nerissa Deparine and interpretation by Dr. Allen Ching.
The defense, in turn, produced testimonies from Arcillas himself and from Barangay Kagawad Jimmy Lorena, who recounted an earlier confrontation where Arcillas signed an affidavit promising not to commit such an act again.

The Regional Trial Court (RTC) in Masbate City convicted Arcillas of qualified rape and imposed the death penalty, along with an award of civil indemnity and moral damages.
On appeal, the Court of Appeals (CA) affirmed the conviction but downgraded it to simple rape, noting that the information failed to properly allege that Arcillas was the common-law spouse of the victim’s mother—a necessary qualifying circumstance for qualified rape.
The CA adjusted the penalty to reclusion perpetua and confirmed the monetary awards, including civil indemnity, moral damages, exemplary damages, and interest.

Whether the information sufficiently stated and proved the qualifying circumstance by alleging that the accused was the common-law spouse (or stepfather) of the victim, which is essential to elevate the crime from simple to qualified rape.
Whether the misallegation of relationship deprived Arcillas of his right to be properly informed of the nature and cause of the accusation against him.

Whether the evidentiary findings, particularly the victim’s detailed and corroborated testimony, were sufficient to establish the commission of rape despite the discrepancies surrounding the accused’s relationship to the victim.
Whether the explanation and denial tendered by Arcillas, based on his claim of only touching the victim during a state of intoxication, could be accorded any weight in light of the stronger evidence presented.

Whether the appropriate imposition of the death penalty was precluded by the defective allegation in the information and by subsequent statutory changes, such as R.A. No. 9346.
Whether the awards for civil indemnity, moral damages, and exemplary damages were properly rendered given the aggravating circumstances even if the offence could only be convicted as simple rape.