G.R. No. 231358 - People vs. Avelino, Jr. y Gracillian

The appellant, Ernesto Avelino, Jr. y Gracillian, was charged with rape committed in May 2006 in Caloocan City.
The charge stemmed from an incident involving the rape of AAA—a 15-year-old minor allegedly suffering from mental retardation—under Republic Act No. 7610.
The Information stated that the accused, using force, threats, and intimidation (armed with a knife), willfully and unlawfully committed carnal knowledge of the victim without her consent.

AAA testified that she was initially engaged in her routine when, after putting the appellant’s son to sleep in the second floor of the appellant’s house, she attempted to leave.
While leaving, she was intercepted by the appellant, who brandished a knife and threatened to kill her and her family.
The testimony detailed the sequence of events: the appellant ordered her to lie down, undressed her despite her resistance, and proceeded to commit the rape by forcibly penetrating her.
Subsequent actions included the appellant’s instruction for her to refrain from informing her parents until later, when relocating and pregnancy led to the disclosure of the incident.
Forensic evidence was introduced via an anogenital examination performed at the PNP Crime Laboratory, where a shallow healed laceration on AAA’s hymen was noted, consistent with blunt penetrating trauma.

The appellant, in his defense, maintained that he did not personally know AAA and denied any involvement in her care or interaction with her.
He claimed his residence was separate from the house rented by AAA’s family from his father, and he asserted that his wife oversaw their children.
The defense contended that, on the day of the alleged incident, neither he nor his family left their house—thus, no opportunity existed for the commission of the alleged crime.
Appellant’s father corroborated the defense by clarifying the leasing arrangement and affirming that adequate care was provided for the appellant’s children whenever he was away.

During pre-trial, the prosecution and defense stipulated critical issues: the jurisdiction of the RTC, the identity of the appellant, confirmation that the victim was a minor (supported by AAA’s birth certificate), and the existence of a medico-legal certificate.
The medico-legal evidence, notably the Medico-Legal Report No. R06-1894 by PSI Antonio (later testified to by PCI Baluyot), supported the occurrence of blunt force trauma and a healed laceration on the victim’s hymen.

The Regional Trial Court (RTC) of Caloocan City, Branch 131, found the prosecution to have discharged its burden by proving beyond reasonable doubt that the appellant committed rape.
The RTC sentenced the appellant to reclusion perpetua and ordered him to pay civil indemnity, moral damages, and exemplary damages in the amounts of P50,000.00 each.
The Court of Appeals (CA) later affirmed the RTC’s conviction with modification, reducing the exemplary damages to P30,000.00 but upholding the substantive conviction.
Dissatisfied with the CA decision, the appellant subsequently elevated the case to the Supreme Court by filing an appeal.

Whether the appellant is guilty of rape beyond reasonable doubt based on the presented evidence.
Whether the RTC erred in convicting the appellant by giving substantial weight to the consistent testimony of AAA despite the defense’s denial.
Whether the imposition of reclusion perpetua was appropriate or if the penalty under Section 5 of RA 7610 should have applied.
Whether the defense’s contention regarding inconsistencies in AAA’s testimony and the alleged lack of credibility is valid.