Case Digest (G.R. No. 171348)
Facts:
In People of the Philippines vs. Larry Erguiza (G.R. No. 171348, November 26, 2008), the 13-year-old victim AAA alleged that on January 5, 2000, at about 5:00 p.m. in the mango orchard behind Bical Norte Elementary School in Bayambang, Pangasinan, accused-appellant Larry Erguiza forcibly raped her at knifepoint. The Information charged him under Article 266-A(1)(a) in relation to Article 266-B of R.A. 8353 and R.A. 7659. At the Regional Trial Court (RTC) of San Carlos City, Branch 57, AAA, her parents (BBB and CCC), and Dr. James Sison testified for the prosecution, while the defense presented five witnesses, including AAA’s playmate Joy Agbuya—who contradicted the victim’s account—and Juanita Angeles, the hilot who corroborated appellant’s alibi. The RTC found Erguiza guilty of rape, sentenced him to reclusion perpetua, and awarded P50,000 each for civil indemnity, moral and exemplary damages, plus child support. The Court of Appeals affirmed the conviction on November 18, 2005Case Digest (G.R. No. 171348)
Facts:
- Alleged Commission of Rape
- On January 5, 2000 at about 5:00 PM, AAA (13-year-old) was picking fallen mangoes at the back of Bical Norte Elementary School in Bayambang, Pangasinan with friends Joy and Ricky Agbuya. AAA’s shorts got hooked on the fence; the siblings allegedly ran off, leaving her alone.
- Larry Erguiza, armed with a kitchen knife, purportedly grabbed AAA, threatened her into silence, dragged her to a tamarind tree area, removed both their garments and forced sexual intercourse. He then threatened to kill her and her family if she spoke about the incident.
- Investigation and Trial
- AAA did not immediately report the incident. On April 7, 2000 her mother (BBB) took her to a “hilot” grandmother in Tarlac who detected pregnancy. AAA disclosed the rape. On April 8, 2000 they reported the incident to police; Dr. James Sison examined AAA, noting a healed hymenal laceration at 11 o’clock.
- Information for rape was filed in RTC, to which appellant pleaded not guilty. Prosecution witnesses: AAA, her parents (BBB, CCC), Dr. Sison. Defense witnesses: Joy Agbuya, orchard caretaker Juanito Macaraeg, hilot Juanita Angeles, appellant’s mother Albina Erguiza, and appellant himself.
- On November 27, 2000, RTC convicted appellant of rape (Art. 266-A §1(a), in relation to RA 8353 & 7659), sentenced him to reclusion perpetua and awarded damages. On November 18, 2005, the Court of Appeals affirmed with modification (reduced exemplary damages). Appellant appealed to the Supreme Court.
Issues:
- Whether the prosecution established appellant’s guilt beyond reasonable doubt given conflicting testimonies.
- Whether the testimony of AAA, a minor, was so credible as to override the alibi and contradictory defense evidence.
- Whether appellant’s alibi—corroborated by Juanita Angeles and Joy Agbuya—creates reasonable doubt.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)