G.R. No. 188108 - People vs. Milagrosa

On March 3, 2004, around 7:00 in the morning, in the Province of Quezon, a 16-year-old minor – identified in the record as AAA – was alone in her residence after having finished washing the dishes.
Evilio Milagrosa, later identified as the accused, entered the scene and forcibly grabbed the victim, carrying her to a grassy area outside the house.

During the struggle, despite AAA’s resistance, Milagrosa overpowered her; his physical strength, attributed to his occupation as a carpenter, was noted as capable of subduing a minor.
The victim observed a balisong at Milagrosa’s waist, which heightened her fear; Milagrosa used this fact to intimidate her further.
Milagrosa removed AAA’s clothes and proceeded to commit rape by forcibly inserting his penis into her vagina, thereby consummating the sexual assault.
After the act, Milagrosa cautioned AAA to keep silent about the incident, augmenting the coercion and control over the situation.

The sole witness for the prosecution was AAA, who testified regarding the assault, recounting that Milagrosa was a known associate and friend of her father.
AAA's testimony included details on the remote and isolated location of the residence, describing how the neighboring houses were not visible from her home, which explains the absence of immediate witnesses in the incident.
Despite the defense's arguments regarding the physical possibility of the assault in broad daylight, AAA's direct account and the isolated setting were significant in establishing the occurrence of the crime.

At trial before the Regional Trial Court (RTC), Branch 63, Calauag, Quezon, AAA’s testimony was deemed credible, leading to the conviction of Milagrosa for rape.
The RTC sentenced Milagrosa to reclusion perpetua and imposed civil indemnity and moral damages amounting to P50,000.00 each in favor of the victim.
On appeal, the Court of Appeals (CA) affirmed the RTC's findings, holding that the victim’s positive and competent testimony established the appellant’s guilt beyond reasonable doubt.

Milagrosa claimed it was physically unlikely he could have carried the victim given that it was early morning and the neighbor's attention might have been alerted by her screams.
He argued that the victim could have grabbed his balisong and defended herself, challenging the plausibility of the account.
An alibi was presented by the defense, asserting that Milagrosa was at Camp Crame at the time of the incident, though no corroborating evidence or witnesses were produced to substantiate this claim.

Whether the positive and competent testimony of AAA, as the sole witness, established the guilt of the accused beyond reasonable doubt.
Whether the isolated location and circumstances presented credible explanations for the absence of additional witnesses.

Whether it was plausible for Milagrosa, despite being 55 years old, to overpower and forcibly carry a 16-year-old girl from her residence to a grassy area during the early morning hours.
Whether the victim’s inability to physically resist or utilize the accused’s balisong constituted sufficient evidence of coercion and inability to defend herself.

The credibility and verifiability of Milagrosa’s alibi that he was at Camp Crame at the time of the incident.
Whether the lack of corroborating evidence for the alibi weakens the defense’s position against the victim’s testimony.