Title
Supreme Court
People vs. Ronquillo
Case
G.R. No. 214762
Decision Date
Sep 20, 2017
Accused convicted of statutory rape of an 11-year-old; conviction upheld by Supreme Court based on credible testimony, medical evidence, and weak defense. Damages modified.

Case Digest (G.R. No. 214762)
Expanded Legal Reasoning Model

Facts:

  • Background of the Case
    • The case involves the People of the Philippines as plaintiff-appellee and Rommel Ronquillo as accused-appellant.
    • The offense charged is statutory rape, defined under Article 266-A in relation to Article 266-B of the Revised Penal Code, as amended by Republic Act No. 8353.
    • The victim, a minor referred to as "AAA" (with her real identity withheld), is central to the case, with her age and testimony being pivotal.
  • Chronology and Details of the Incident
    • On October 3, 2001, the charge-sheet describes the accused committing the offense in the Municipality of xxx, Province of xxx.
    • The incident occurred when AAA, then eleven (11) years old, was returning from an evening activity.
    • According to the prosecution’s narrative, after AAA participated in an amateur singing contest, she was noticed by the accused at a waiting shed.
    • The accused approached her, followed her home, and eventually forced her to an isolated area where the rape occurred.
    • The crime involved physically subduing and assaulting AAA, using force, a weapon (a gun during the incident to intimidate), and intimidation.
    • AAA provided a detailed account of the sequence of events, including the moment when the assailant removed his disguise (a red handkerchief) that initially obscured his face.
  • Testimonies and Physical Evidence
    • Prosecution Testimonies
      • AAA gave a steady, vivid, and consistent deposition reciting her ordeal from being followed to the act of rape.
      • Dr. Stella Guerrero-Manalo from the UP-PGH Child Protection Unit testified after conducting a medical examination on AAA, revealing fresh lacerations and injuries on her genital area consistent with a recent penetration injury.
    • Defense Testimony
      • The accused testified in his own defense, claiming an alibi that he was attending a barrio fiesta, participating in singing and other activities, and asserted he did not even know AAA prior to the incident.
      • His defense rested on denial and an uncorroborated alibi, which did not withstand judicial scrutiny.
  • Procedural History
    • The Regional Trial Court (RTC) of Angeles City, Branch 60, found the accused guilty beyond reasonable doubt on November 23, 2010. The RTC sentenced him to reclusion perpetua and imposed civil indemnity and moral damages.
    • On appeal, the Court of Appeals (CA) affirmed the RTC’s decision on November 11, 2013, with the modification of the damages award, reducing and supplementing the monetary awards.
    • The Supreme Court eventually reviewed the case, emphasizing consistency with established jurisprudence on statutory rape.

Issues:

  • Central Issue
    • Whether or not the conviction of accused-appellant Rommel Ronquillo for the crime of statutory rape must be upheld.
  • Evidence and Credibility
    • Whether the detailed testimony of the minor (AAA) and the corroborative medical evidence sufficiently established the elements of carnal knowledge despite the accused’s denial and alleged alibi.
    • Whether the accused’s defenses—denial of involvement and the alibi—are credible or substantiated by strong evidence.
  • Assessment of Damages
    • Whether the revised award of damages (civil indemnity, moral, and exemplary damages) as modified by the CA should be maintained or further adjusted.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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