Title
Supreme Court
People vs. Claro y Mahinay
Case
G.R. No. 199894
Decision Date
Apr 5, 2017
Accused acquitted of rape due to reasonable doubt; prior relationship, voluntary actions, and lack of conclusive evidence of force led to acquittal.

Case Digest (G.R. No. 199894)
Expanded Legal Reasoning Model

Facts:

  • The Case and Antecedents
    • Carlito Claro y Mahinay was charged with rape under an information alleging that on March 14, 2006 in Manila, he lured AAA by text, took her to Jollibee and thereafter to Aroma Motel where he locked the door, pulled her onto the bed, undressed her and forcibly had carnal knowledge of her against her will.
    • The Regional Trial Court (RTC), Branch 21, Manila rendered judgment on November 17, 2008 finding him guilty beyond reasonable doubt and sentencing him to reclusion perpetua with civil indemnity and moral damages. The Court of Appeals (CA), Third Division, affirmed on March 24, 2011 (CA-G.R. CR-H.C. No. 03702).
  • Prosecution Evidence
    • Victim’s testimony: AAA recounted receiving a text invite, taking a jeepney to Rizal Avenue, eating at Jollibee, resisting entry to the motel, attempting to flee, calling her cousin (a police officer), and ultimately being overpowered, undressed and raped. She reported the incident, set a meeting under her cousin’s instruction, and the accused was apprehended.
    • Medico-legal findings: Dr. Wilfredo Tierra documented a fresh deep hymenal laceration with bleeding, an abrasion (1.3 cm) on the left breast, and a contusion (1.5 cm) on the right hand.
  • Defense Evidence
    • Accused’s testimony: Claimed a prior consensual romantic relationship with AAA since January 2006, that they willingly agreed to a date on March 14, went together to the motel, had mutual consent for sexual intercourse, and only parted when AAA later called the police.
    • Mother’s testimony: Stated AAA was already her son’s girlfriend, and alleged that AAA’s cousin demanded ₱200,000 to refrain from further discussion.
  • Rulings Below
    • RTC conviction: Found guilt proven beyond reasonable doubt, sentenced to reclusion perpetua, ordered payment of ₱50,000 civil indemnity and ₱50,000 moral damages.
    • CA affirmation: Upheld RTC’s credibility assessment of AAA, viewed bruises and abrasions as proof of force and bodily harm, and accepted her explanation for traveling home with the accused.

Issues:

  • Whether the RTC and the CA correctly found and pronounced the accused guilty of rape beyond reasonable doubt.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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