G.R. No. 179271 - Barangay Association for National Advancement and Transparency vs. Commission on Elections

The case involves the People of the Philippines versus Ricardo Piosang, also known as Ricric, who was charged with raping a minor (designated as AAA).
The criminal complaint was initiated upon the sworn complaint of AAA’s mother, leading the City Prosecutor of Quezon City to file an Information on January 8, 1999.
The offense was charged as statutory rape under Article 266-A of the Revised Penal Code in relation to Section 5(b) of Article III of R.A. 7610.

On July 8, 1998, AAA, while playing with friends, was invited by her neighbor CCC to go to the accused’s house.
According to the prosecution, AAA and CCC were forced into the comfort room of Ricardo Piosang’s residence.
Inside the detached comfort room, the accused allegedly used a knife to threaten the children, ordering them to remain silent under the threat of death.
The accused is said to have removed his short pants and applied a reddish substance on his penis before inserting it into AAA’s vagina while she stood atop the toilet bowl.
Subsequently, during the assault, the accused allegedly ordered CCC to “pretend” to perform a similar act; CCC’s actions were described as mimicry while the accused masturbated and wiped his semen on the victim’s mouth.
After committing the act, the accused threatened the children to keep silent and even offered AAA a five-peso coin prior to letting her go home.
AAA did not immediately report the incident; however, months later, during an interaction with her mother, she disclosed details which pointed to the accused.

AAA, the minor victim, whose direct and detailed testimony identified the accused as the perpetrator.
BBB, AAA’s mother, who corroborated the disclosure of the assault.
CCC, a minor neighbor who witnessed the events and whose testimony further corroborated the sequence of events in the comfort room.
DDD, the mother of CCC, who provided additional background on the child witness’s account, including the incident when CCC was confronted.
P/Sr. Inspector Mary Ann Gajardo, who testified on behalf of Dr. Tomas Suguitan, the medico-legal officer responsible for examining AAA.

Physical evidence included the findings from the medico-legal examination which noted shallow healed lacerations at specific positions on AAA’s genital area and a non-virgin physical state, supporting the allegation of sexual abuse.

The defense, through the accused and his mother Remedios Piosang, denied the charge of rape.
The accused claimed that he was at home letting his hair dry at the garage on the day of the incident, and asserted that a neighbor’s information led him to the scene after hearing CCC’s crying.
The accused pointed to CCC as the actual perpetrator, basing his argument on CCC’s initial hesitance to divulge the incident and subsequent events, including an alleged altercation where CCC was whipped by his own mother DDD.
Additional defense allegations included a claim that an attorney from the Office of the Vice Mayor attempted to settle the case in exchange for money, implying a cover-up to shift blame to CCC.
Procedurally, the Regional Trial Court (RTC) of Quezon City, Branch 94, rendered its decision on November 26, 2009, finding the accused guilty beyond reasonable doubt and sentencing him to reclusion perpetua along with the imposition of civil indemnity and damages.
The Court of Appeals, in a decision dated April 28, 2011, affirmed the RTC’s ruling with modifications to the damage awards.
The accused-appellant elevated the case to the Supreme Court, contesting the adequacy of the prosecution’s evidence and insisting that his guilt was not established beyond a reasonable doubt.

Whether the trial court erred in convicting Ricardo Piosang of statutory rape despite the defense’s claims of an alibi and alternate theory implicating CCC as the perpetrator.
Whether the evidence, primarily the direct and detailed testimony of the minor victim AAA, supplemented by corroborative testimonies (from BBB, CCC, and others) and physical findings, was sufficient to establish the accused’s guilt beyond reasonable doubt.
Whether the appellate courts were correct in giving the trial court’s factual findings, particularly in weighing the credibility of the witnesses (notably the minor victim's clear identification of the accused) over the defense’s self-serving denial and alibi.