Title
People vs. Court of Appeals
Case
G.R. No. 183652
Decision Date
Feb 25, 2015
A 16-year-old minor, intoxicated and unconscious, was sexually assaulted by three men. Despite initial acquittal, the Supreme Court reversed, convicting them of rape, citing lack of consent and credible testimony.

Case Digest (G.R. No. 147079)
Expanded Legal Reasoning Model

Facts:

  • Parties and Charges
    • On June 23, 2004, AAA (a 16-year-old minor) filed a Second Amended Information charging Raymund Carampatana, Joefhel Oporto, Moises Alquizola, and others with rape under Article 266-A of the Revised Penal Code for acts committed on March 25–26, 2004, in Lala, Lanao del Norte.
    • The Information alleged that the accused conspired to intoxicate AAA with Emperador Brandy, brought her to a lodging house, and had carnal knowledge of her against her will.
  • Trial and Appeals
    • RTC of Kapatagan, Branch 21 (Feb. 28, 2006) convicted Carampatana and Oporto of rape and Alquizola as accomplice; acquitted five co-accused for lack of proof.
    • Court of Appeals (CA) 21st Division (June 6, 2008) reversed and acquitted Carampatana, Oporto, and Alquizola, finding the victim consented and giving weight to defense testimony and medical findings of an old hymenal laceration.

Issues:

  • Procedural Issues
    • Whether AAA, as private offended party, may validly invoke Rule 65 certiorari against the CA acquittal without violating double jeopardy or the requirement to file a motion for reconsideration.
    • Whether the Solicitor General’s intervention is necessary or whether AAA may proceed in her own name.
  • Substantive Issue
    • Whether the CA committed grave abuse of discretion amounting to lack of jurisdiction by disregarding the prosecution’s evidence and improperly acquitting the respondents.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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