G.R. No. 45310 - Rotea vs. Delupio

The accused, Jerry Bugna y Britanico, was charged in two separate informations for the crime of Qualified Rape as defined under Article 266-B(1) of the Revised Penal Code.
In the first information, dated 28 March 2008, Bugna was accused of raping AAA on or about 7 April 2007 at around 8:00 P.M. at their own house in South Cotabato. The accusatory portion detailed that by means of force, threat, and intimidation Bugna committed carnal knowledge on a 16-year-old victim without her consent.
In a separate information of the same date, he faced a second charge for an incident on or about 21 December 2007 at around 2:00 A.M. in the same location. The allegations likewise contended that Bugna used similar means of force or intimidation to rape the same minor victim.

The primary witness, AAA, testified in detail about the incidents. In the first incident, she recounted that while she and her siblings were about to sleep, Bugna, coming home intoxicated, removed her shorts, inserted his finger, and later mounted and penetrated her sexually.
In the second incident, AAA testified that despite trying to resist by attempting to run and shout, Bugna overpowered her, ordered her to lie down, and forcibly raped her.
Medical evidence provided by Dr. Neil T. Crespo supported AAA’s claims, noting healed lacerations on her genital area as observed during a physical examination on 2 January 2008.

Bugna, as the sole defense witness, testified that he was away from home during the period from April 2007 to December 2007.
He stated that he traveled to Tacurong, Sultan Kudarat from 4 April 2007 to 1 May 2007, and from then until 31 December 2007, he was reportedly in Bayugan, Agusan del Sur, thereby attempting to establish an alibi.
No disinterested witnesses or corroborative evidence substantiated his claim of absence from the scene of the incidents.

The Regional Trial Court (RTC) rendered a decision on 15 May 2012 finding Bugna guilty beyond reasonable doubt on both counts of rape, emphasizing the credibility of AAA’s positive identification and the consistency of her testimony.
The RTC sentenced Bugna to suffer the penalty of reclusion perpetua for each count and ordered him to pay damages to the victim.
On appeal, the Court of Appeals (CA) in its decision on 17 December 2014 substantially affirmed the RTC’s finding of guilt, modifying only the award of damages by increasing the amounts awarded as civil indemnity, moral damages, and exemplary damages.
Bugna’s appeal to the Supreme Court (as indicated by this case being an appeal) was ultimately denied, with the appellate courts reiterating the sufficiency and credibility of the evidence against him.

Whether the evidence, particularly AAA’s testimony and the corroborative medical findings, was sufficient to convict Bugna beyond reasonable doubt of the crime of Qualified Rape.
Whether the accused’s alibi, relying solely on his own assertion without corroboration from disinterested witnesses, could counteract the positive identification and consistent testimony of the victim.
Whether the absence of physical resistance by the victim—in the context of the overpowering influence from the accused—negates the presence of force or intimidation in the commission of the crime.
Whether the modifications to the award of damages, in line with recent jurisprudence and statutory provisions, are justified given the circumstances of the case.