Facts:

The case involves Gerald Ballacillo, the accused-appellant, who was charged with multiple counts of rape against his 15-year-old niece, referred to as AAA. The incidents occurred in April 1999 in Lagangilang, Abra, Philippines. The first incident took place on April 14, 1999, when Ballacillo, while gathering bamboo shoots with AAA, forcibly had carnal knowledge of her under threat of a knife. The subsequent incidents occurred on April 27 and April 29, 1999, where he again assaulted AAA in similar circumstances, using threats to ensure her compliance. AAA did not report the incidents immediately due to fear of retaliation from Ballacillo and concern for her family's well-being, particularly her father's violent temper. It was only in September 1999 that she confided in a friend, and later, her mother learned of her pregnancy, which was confirmed by medical examination.

Ballacillo denied the charges, claiming he was attending a youth seminar during the times of the a...

Facts:

1. Background of the Case:

   • Gerald Ballacillo (accused-appellant) was charged with four counts of rape in separate Informations filed before the Regional Trial Court (RTC) of Bangued, Abra. The victim, AAA, was his 15-year-old niece.
   • The alleged rapes occurred on April 14, 17, 27, and 29, 1999, in Lagangilang, Abra. AAA became pregnant as a result of the rapes and gave birth on January 18, 2000.

2. Prosecution’s Evidence:

   • AAA testified that Ballacillo raped her on multiple occasions, using force, intimidation, and threats. He threatened to kill her and her family if she reported the incidents.
   • On April 14, 1999, Ballacillo raped AAA in a woody area after taking her to gather bamboo shoots. He used a knife to intimidate her.
   • On April 27 and 29, 1999, Ballacillo raped AAA while she was asleep in her home, covering her mouth and threatening her with violence.
   • AAA did not immediately report the rapes due to fear of Ballacillo’s threats and her father’s violent temper. She only confided in a friend in September 1999, and her mother learned of the pregnancy in October 1999.
   • Medical findings by Dr. Liberty Banez confirmed AAA’s pregnancy and corroborated her testimony that the rapes occurred in April 1999.

3. Defense’s Evidence:

   • Ballacillo denied the charges, claiming he was attending a Catholic youth recollection seminar during the alleged dates of the rapes. He presented witnesses (Jonathan, Jordan, and Darwin Crisologo) to corroborate his alibi.
   • Ballacillo also alleged that his brother, Sonny Boy, was the father of AAA’s child, claiming that Sonny Boy had a romantic relationship with AAA.

4. RTC and CA Decisions:

   • The RTC convicted Ballacillo of three counts of rape (Criminal Cases No. 1999-419, 2000-22, and 2000-23) but acquitted him in Criminal Case No. 2000-21 due to lack of evidence. He was sentenced to reclusion perpetua for each count and ordered to pay civil indemnity and moral damages.
   • The Court of Appeals (CA) affirmed the RTC’s decision with modifications, increasing the awards for civil indemnity, moral damages, and exemplary damages.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Credibility of the Victim’s Testimony:

   • In rape cases, the credibility of the victim’s testimony is crucial. AAA’s testimony was found to be credible, consistent, and corroborated by medical evidence. Youth and immaturity are badges of truth, and AAA’s straightforward account was sufficient to establish the elements of rape.

2. Elements of Rape:

   • The prosecution proved all elements of rape under Article 266-A of the Revised Penal Code, as amended: (a) carnal knowledge of a woman, (b) through force, threat, or intimidation.

3. Defense of Alibi and Denial:

   • Ballacillo’s alibi was deemed weak and uncorroborated by credible evidence. The proximity of his location during the alleged rapes made his alibi implausible.

4. Delay in Reporting:

   • The delay in reporting the rapes was justified by the victim’s fear of Ballacillo’s threats and her concern for her family’s welfare.

5. Damages:

   • The Court increased the awards for damages in line with recent jurisprudence, ensuring that the victim receives adequate compensation for the harm suffered.