Title
People vs. Rullepa y Guinto
Case
G.R. No. 131516
Decision Date
Mar 5, 2003
A 3-year-old minor was raped by accused-appellant, who admitted to the act. Medical evidence and testimony corroborated the crime. The Supreme Court affirmed guilt, modifying the penalty to reclusion perpetua due to insufficient proof of the victim's exact age.

Case Digest (G.R. No. 131516)
Expanded Legal Reasoning Model

Facts:

  • Criminal Charge and Arraignment
    • Accused-appellant Ronnie Rullepa y Guinto, a 28-year-old houseboy, was charged with rape of AAA, a three-and-a-half-year-old minor, allegedly committed on November 17, 1995 in Quezon City by force and intimidation.
    • Accused was arraigned on January 15, 1996 and pleaded not guilty.
  • Disclosure and Confrontation
    • On November 20, 1995, AAA told her mother, Gloria Buenafe, that “Kuya Ronnie” had inserted his penis into her vagina, anus, and mouth many times.
    • Gloria confronted accused, who initially admitted the assault once at 4:00 p.m. of November 17, 1995.
  • Medical Examination
    • Dr. Ma. Cristina V. Preyra’s medico-legal report (November 21, 1995) found congested and abraded labia minora, an intact hymen, and concluded the abrasions were consistent with friction from an erect penis.
    • No external signs of other trauma were noted; the victim was declared physically a virgin state.
  • Trial Proceedings and RTC Decision
    • Prosecution witnesses: AAA, her mother, Dr. Preyra, and SPO4 Borda. AAA gave detailed, consistent testimony of the assault.
    • Accused denied the charges, alleging ill motive by the mother.
    • RTC Branch 96 convicted accused of rape, sentenced him to death, and awarded AAA ₱40,000 civil indemnity.

Issues:

  • Whether the trial court erred in admitting accused’s extra-judicial admission.
  • Whether accused’s silence at trial constituted an implied admission of guilt.
  • Whether the prosecution proved guilt beyond reasonable doubt.
  • Whether the death penalty was properly imposed.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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