Case Digest (G.R. No. 200793)
Facts:
People of the Philippines v. Milan Roxas y Aguiluz, G.R. No. 200793, June 04, 2014, Supreme Court First Division, Leonardo-De Castro, J., writing for the Court.The prosecution charged Milan Roxas y Aguiluz (accused-appellant) by five separate Informations (Crim. Case Nos. Q-00-91967 to Q-00-91971) with five counts of rape against his niece, identified in the record as AAA (a minor). The Informations alleged that the rapes occurred between September 16, 1997 and August 9, 1998 in Quezon City and frequently involved blindfolding, removal of clothing, the insertion of a pointed weapon, and carnal knowledge. Accused pleaded not guilty.
At trial, the prosecution's principal evidence was the testimony of AAA, who recounted five separate incidents in which she was taken to bedrooms or a bathroom, blindfolded, threatened with a pointed instrument, and raped by accused. She testified that she was 9 years old at the time of the first incident and 10 years old for the subsequent incidents and that accused threatened to cut her tongue or kill her and her mother if she told anyone. The defense presented four witnesses: AAA's mother (BBB), two brothers (DDD and EEE), and Dr. Agnes Aglipay, a Regional Psychiatrist who testified that accused had a mild mental retardation with a mental age of nine to ten years despite being chronologically eighteen.
On December 11, 2007, the Regional Trial Court (Branch 94, Quezon City) rendered judgment finding accused guilty beyond reasonable doubt on all five counts and sentenced him to reclusion perpetua on each count, ordered indemnity and moral damages and credited detention. The RTC found AAA credible and rejected the defense witnesses as flimsy and largely hearsay; the RTC also held accused not exempt from criminal responsibility despite his reported low mental age.
Accused appealed to the Court of Appeals (docketed CA-G.R. CR.-H.C. No. 03473). On August 16, 2011, the Court of Appeals affirmed the RTC decision with modification: it ordered accused to pay, for each count, civil indemnity of P75,000, moral damages of P75,000 and exemplary damages of P30,000. Accused filed an appeal to the Supreme Court, challenging the trial court’s credibility findings and arguing that, under Republic Act No. 9344 (the Juvenile Justice and Welfare Act), his mental age should exempt him from criminal liability despite his chronological age.
The Supreme Court First Division took up the appeal. The parties’ arguments focused on (a) the credibility and sufficiency of AAA’s testimony to sustain conviction, (b) whether accused’s alleged ...(Subscriber-Only)
Issues:
- Whether accused-appellant’s asserted mental age excuses him from criminal liability under Republic Act No. 9344, Sec. 6 despite his chronological age of 18 at the time of the offenses.
- Whether the testimony of the minor complainant (AAA) was sufficiently credible to sustain convictions beyond reasonable doubt.
- Whether the Informations sufficiently alleged qualifying circumstances (minority and relationship) to permit imposition of a greater penalty and whether the p...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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