Title
People vs. Jacinto
Case
G.R. No. 182239
Decision Date
Mar 16, 2011
A 17-year-old convicted of raping a 5-year-old; alibi rejected, minor’s testimony and medical evidence upheld; reclusion perpetua affirmed.

Case Digest (G.R. No. 182239)
Expanded Legal Reasoning Model

Facts:

  • Commission of Crime
    • On January 28, 2003, at around 7:00 p.m. in barangay XXX, Hermie M. Jacinto allegedly had carnal knowledge of five-year-old AAA in a rice field near the Perochos’ house: he removed her panty, mounted her in a push-pull movement, causing pain and bleeding.
    • AAA ran home crying, barefoot and soiled; FFF (father) found contusions on her neck, mud on her head, blood oozing, whitish mucoid material on her genitals, and a contusion on her chest.
  • Pre-trial and Trial Evidence (Prosecution and Medical)
    • Information filed March 20, 2003 in the Regional Trial Court as Criminal Case No. 1679-13-141; charged rape qualified by minority; appellant pleaded not guilty July 15, 2003.
    • Prosecution witnesses: AAA positively identified Jacinto; FFF and Julito Apiki saw Jacinto holding AAA’s hand at the store, confronted him later.
    • Medical findings: Dr. Bernardita M. Gaspar’s certificate noted hymenal lacerations at 5 o’clock and 9 o’clock positions and genital soiling; Dr. Christine Ruth B. Micabalo confirmed penetration injuries.
  • Defense Evidence and Alibi
    • Appellant’s alibi: attended a birthday party at the Perochos’ from morning; was sent to buy a bottle of rum (returned in 3–5 minutes as shown by his watch); witnesses Aunt Gloria, Luzvilla Balucan, and Antonia Perocho testified he remained at the party.
    • Alternative suspect: Luzvilla and Antonia claimed Julito, not appellant, carried AAA; their accounts conflicted on times, clothing (shirt color), presence of other persons, and sequence of events.
  • Procedural History
    • Trial court decision (March 26, 2004) convicted Jacinto of rape and sentenced him to death, plus P75,000 indemnity and P50,000 moral damages; on April 6, 2004, amended to reclusion perpetua upon proof he was 17 at the time of the offense.
    • Court of Appeals (August 29, 2007) affirmed conviction, imposed indeterminate sentence (6 years 1 day to 12 years prision mayor minimum; 17 years 4 months reclusion temporal maximum), awarded P75,000 civil indemnity, P75,000 moral damages, P25,000 exemplary damages; allowed appeal to the Supreme Court.
    • Supreme Court required supplemental briefs and rendered decision on March 16, 2011.

Issues:

  • Whether the prosecution proved appellant’s guilt beyond reasonable doubt despite the defense of alibi and conflicting testimonies.
  • How appellant’s minority at the time of the offense and Republic Act No. 9344 (Juvenile Justice and Welfare Act) affect the proper penalty and disposition.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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