Case Digest (G.R. No. 222497)
Facts:
People of the Philippines v. Pedro Rupal, G.R. No. 222497, June 27, 2018, Supreme Court Third Division, Martires, J., writing for the Court. The accused-appellant is Pedro Rupal; the prosecution is the People of the Philippines. The alleged offended party is a minor identified in the record by the initials AAA.On or about December 15, 2005, AAA, then a thirteen‑year‑old high‑school student, accused Pedro Rupal of dragging her from a waiting shed to a nearby coconut plantation, pushing her to the ground, removing her underwear, and inserting his penis into her vagina by force, threat and intimidation. AAA initially did not disclose the incident because Rupal allegedly threatened to kill her mother and siblings; she later told her mother (BBB) and, on January 4, 2006, filed a statement with the police. AAA also reported being raped several times beginning when she was nine years old. On January 9, 2006, Dr. Analita N. Auza examined AAA and found healed lacerations at the vaginal opening (2, 7 and 11 o’clock), a non‑intact hymen, and evidence of vaginal penetration.
An information for rape (docketed Crim. Case No. 06‑1748) was filed. At arraignment, Pedro Rupal pleaded not guilty. The prosecution presented AAA, her mother BBB, and Dr. Auza. The defense anchored on denial and an alibi: Rupal testified he spent the day cleaning the garden, fetching water, and staying at home; he also suggested a family feud (between BBB and his wife DDD) as motive for fabrication. Rupal did not execute a counter‑affidavit upon arrest and called no other witnesses to corroborate his alibi.
The Regional Trial Court (RTC) found AAA’s testimony credible, held that the elements of rape under Article 266‑A (as amended by R.A. No. 8353) were proven, convicted Rupal of rape and sentenced him to reclusion perpetua with civil indemnity of P50,000.00 (Decision dated September 5, 2012). Rupal appealed to the Court of Appeals (CA). The CA, Twentieth Division, affirmed the conviction but modified damages, ordering ...(Subscriber-Only)
Issues:
- Did the courts below err in giving weight and credence to AAA’s testimony despite alleged inconsistencies and improbabilities?
- Did the prosecution fail to prove accused‑appellant’s guilt beyond reaso...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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