G.R. No. 230723 - People vs. Villanueva y Bautista

On July 27, 2006, in Antipolo City, AAA, a fifteen-year-old minor, was abducted by a group of unidentified individuals led by, among others, Jupiter Villanueva y Bautista (“Peter”).
The abduction occurred when the victim was walking near Gate 2, San Isidro, and was accosted by two masked men wielding a bladed weapon.
The incident involved not only the forcible abduction by means of a tricycle but also subsequent sexual assault, where the victim was forced into having intercourse, accompanied by additional forms of physical abuse.
The charge was filed under Section 5(b) of Republic Act (RA) No. 7610 and Section 5(a) of RA 8369, which address the offenses of forcible abduction with rape.

During arraignment, the accused pleaded not guilty, and the parties later stipulated on his identity and on the jurisdiction of the trial court.
The prosecution presented key testimonies from:

The victim, AAA, whose harrowing account detailed the abduction and subsequent assault.
AAA’s aunt (BBB), who corroborated the victim’s frantic identification during the police’s intervention.
PC/Insp. Marianne Ebdane, the medico-legal officer who verified the physical injuries consistent with blunt force and penetrating trauma.
SPO1 Ma. Theresa A. Bautista, a witness from the Women’s Child Protection Desk, who confirmed AAA’s identification of the accused.

The defense relied solely on the accused’s testimony, which asserted an alibi involving his presence at work and with his girlfriend, and a denial of the allegations.

The RTC conducted a thorough evaluation of the evidence and found the testimony presented by AAA credible, noting her consistency and the spontaneous nature of her identification of the accused.
The trial court affirmed that all elements of the crimes of forcible abduction and rape were present:

The circumstances of the abduction and the modus operandi exhibited by the perpetrators.
The physical evidence from the medico-legal examination which indicated the presence of deep lacerations and other marks of blunt force.
Corroborative testimonies from eyewitnesses and accompanying family members.

The accused’s defenses—alibi and denial—were deemed weak, as he failed to prove it was physically impossible for him to be at the scene of the crime.
A finding of conspiracy between the accused and his unidentified accomplices was also made.
Consequently, the RTC convicted the accused and sentenced him to reclusion perpetua, with additional awards for civil indemnity and moral damages.

The accused’s provided alibi was not credible given his proximity to the crime scene.
AAA’s testimony, identification, and the medico-legal findings were upheld as reliable and unaffected by police influence.

The CA increased the awards for civil indemnity and moral damages from ₱50,000.00 to ₱75,000.00 each, with interest accruing at 6% per annum.
The CA also concurred with the trial court’s conclusion regarding the absorption of the offense of forcible abduction into the crime of rape, given the intent to commit sexual assault.

The Supreme Court reviewed the case, finding that the evidence clearly established the occurrence of both forcible abduction and rape.
The Court reiterated that the victim’s unambiguous and credible testimony should be accorded significant evidentiary weight.
The defendant’s alibi was rejected on the basis that the location and timing made it physically possible for him to be present at the scene of the crime.
The final ruling affirmed the conviction for rape, maintained the penalty of reclusion perpetua, and modified the damages to include an award for exemplary damages in addition to the increased civil indemnity and moral damages.

Whether the prosecution established all elements of forcible abduction and rape beyond reasonable doubt.
Whether the physical evidence and victim’s testimony, including the identification of the accused, were sufficient to support a conviction.

Whether the accused’s alibi was credible and supported by evidence showing it was physically impossible for him to be at the scene of the crime.
Whether the defense’s reliance on mere denial could outweigh the consistent and corroborated eyewitness accounts.

Whether AAA’s identification of the accused was subject to any undue influence or direction by the police during the investigation.
Whether the spontaneity and manner of the victim's identification further reinforced its reliability.

Whether increasing the amounts for civil indemnity and moral damages, and adding exemplary damages, was appropriate and in line with previous case law such as People v. Jugueta.