G.R. No. 250934 - People vs. Brillo y De Guzman

On June 17, 2011, the accused-appellant, Melford Brillo y De Guzman, was indicted for the crime of rape under Article 266-A, paragraph 1(b) of the Revised Penal Code (RPC), as amended by RA 8353, in connection with RA 7610.
The Information alleged that on or about October 1, 2010, within a specified locality in the Philippines, the accused, with lewd design, raped a minor identified as “AAA” (15 years old) by inserting his penis into her vagina against her will while she was intoxicated.

The incident occurred during a social gathering involving several individuals where AAA, accompanied by her friend EEE, met FFF and his group.
The group included several companions (GGG, HHH, LLL, JJJ, and KKK) with the accused-appellant present and participating.

The group proceeded to the house of LLL, where a drinking session commenced; AAA chose to drink juice while the others consumed liquor, particularly Emperador Brandy.
AAA was forced to drink liquor when GGG, HHH, LLL, and the accused-appellant improperly placed half-filled glasses of liquor in her mouth, leading to her intoxication.

After the prolonged drinking session (lasting approximately two hours) and upon becoming intoxicated, AAA passed out in a bedroom.
Upon awakening around 9:00 in the evening, AAA discovered herself unclothed and the accused-appellant naked and on top of her.
Despite her attempts to push him away, the accused-appellant escalated his actions by punching her and then forcibly holding her hands while inserting himself into her.
Additional witnesses present in the vicinity (FFF, GGG, HHH, and LLL) appeared to be recording the incident with their cellular phones.

The primary evidence was the testimony of the victim, AAA, which was detailed, categorical, and consistent.
Two other witnesses, BBB and the medical expert Dr. Rolando Marfel Ortiz, provided corroborative testimonies, with Dr. Ortiz’s medico-legal examination revealing lacerations at the 4, 6, and 8 o’clock positions on AAA’s vagina.
The medical findings supported the claim that AAA was physically assaulted while intoxicated and incapable of giving consent.

The accused-appellant testified in his own behalf, presenting an alibi by stating he had been involved in a school cheer dance event earlier that day.
He recounted his version of events, including an encounter with AAA that involved a kiss and a brief embrace, asserting that his actions were misinterpreted.
The defense relied on portraying inconsistencies in AAA’s account and emphasized his homosexuality to suggest that there was no sexual desire or intent toward her.

The RTC gave full credence to the victim’s detailed testimony and the supporting medico-legal certificate, finding that AAA’s state of intoxication rendered her incapable of consenting.
The RTC convicted the accused-appellant of rape and imposed reclusion perpetua, along with monetary awards for moral damages, civil indemnity, and exemplary damages.

The accused-appellant appealed the RTC decision based on claims of incredibility of the victim’s testimony and the alleged insufficiency of proof beyond reasonable doubt.
The Court of Appeals (CA) affirmed the RTC’s judgment with modifications by increasing the amount of damages (moral, civil indemnity, and exemplary) awarded.
Subsequent to the CA’s decision, the case was elevated to the Supreme Court, which reviewed the evidence and the legal standards applied.

Whether AAA’s consistent and detailed testimony, despite minor inconsistencies, is sufficient to establish the occurrence of rape.
Whether the inherent nature and sensitivity of rape cases justify giving full credence to the victim’s account.

Whether the prosecution proved that the accused-appellant had carnal knowledge of the victim, who was rendered incapable of consent due to extreme intoxication and unconsciousness.
Whether the medico-legal certificate and supporting testimonies satisfactorily corroborate the victim’s statement.

Whether the defense’s version, including claims of an alternative sequence of events and absence of intent due to his homosexuality, negates the prosecution’s evidence.
Whether denial and alibi in this context, as supported solely by the accused’s testimony, can overcome the strong testimonial and physical evidence presented by the prosecution.