G.R. No. 259221 - People vs. XXX

The accused-appellant was charged in two separate Informations with the crimes of Rape and Attempted Rape under Article 266-A of the Revised Penal Code in relation to Republic Act No. 7610.
The offenses were committed against a minor victim, AAA, who was 14 years old at the time of the incidents.
The case involved two distinct criminal incidents: one on December 25, 2005, and another on January 5, 2006.

Accused-appellant allegedly encountered the victim at around 8:00 in the evening at a location in Nueva Ecija.
The accused-appellant, returning to the house after having earlier declared his intention to go to his ducks, found the victim alone.
He removed the victim’s clothes and, after undressing himself, proceeded to commit the act by holding the victim’s hands and exerting force.
He used a bladed weapon by poking it at the victim’s neck and instructed her not to tell anyone by threatening to kill her and her family.
The assault culminated in the accused-appellant inserting his penis into the victim’s vagina, after which he kissed her lips and neck.
The incident was characterized by aggravating factors such as nighttime and abuse of confidence, and resulted in the victim experiencing pain and bleeding.

On the morning of January 5, 2006, in another incident at a different location in Nueva Ecija, the accused-appellant allegedly attempted a similar crime.
The victim and her sister were present near a wooden bed in a hut where the accused-appellant, armed with a kitchen knife, forcibly removed the victim’s clothing and ordered her to lie down.
The assault was interrupted when BBB, the victim’s mother, arrived and intervened by striking the accused-appellant with a piece of wood.
Despite the intervention, the events led to further complications in the case as the sequence of events was later subjected to different accounts.

The prosecution presented several witnesses including the victim AAA, her mother BBB, and Dr. Ma. Eilyn F. Basco, who conducted the victim’s medical examination revealing contusions and lacerations consistent with sexual assault.
The victim’s original, detailed testimony was later partially recanted through a Sinumpaang Salaysay ng Pag-uurong ng Habla executed on November 26, 2013, wherein she claimed that the allegations stemmed from a personal misunderstanding with the accused-appellant. However, she subsequently testified against him during trial.
The defense relied on the accused-appellant’s version that he was at his farm during the incident and highlighted the recantation affidavit of the victim, suggesting that the charges were manipulated due to personal animosity.

At arraignment, the accused-appellant pleaded not guilty to the charges.
At the trial level, the Regional Trial Court (RTC) issued a Joint Decision on January 21, 2014, wherein the accused was acquitted of Attempted Rape but convicted of Rape, and was sentenced to reclusion perpetua along with the imposition of monetary penalties on account of civil indemnity and moral damages.
On September 24, 2015, the Court of Appeals (CA) affirmed in toto the RTC’s decision, dismissing the accused-appellant’s appeal and underscoring the general judicial disfavor toward affidavits of desistance or recantation in rape cases.

Whether the prosecution has proven beyond reasonable doubt that the accused-appellant committed the crime of Rape.

Sub-issue: The reliability of the victim’s recantation affidavit in light of her original testimony and the corroborative medical evidence.
Sub-issue: Whether the elements of the crime—carnal knowledge of a woman against her will, executed through force or intimidation—have been sufficiently established.
Sub-issue: The proper designation and classification of the offense, considering the misplaced correlation with Republic Act No. 7610 and the applicable provisions of the Revised Penal Code.