G.R. No. L-12222 - University of San Agustin vs. Court of Industrial Relations

The case involves accused-appellant Maximo Dinoy YbaAez facing multiple criminal charges arising from events in May 2009 in Zamboanga del Norte.
The trial court (RTC, Branch 11, Sindangan) rendered a Joint Decision on February 26, 2018, convicting the accused in Criminal Case Nos. S-4290 and S-4291 for rape, while acquitting him in Criminal Case Nos. S-4292 and S-4225.
The Court of Appeals (CA) affirmed the RTC decision with modifications on damages, and the present appeal seeks the acquittal of the accused based on alleged insufficiency of evidence.

Three counts of rape under Article 266-A of the Revised Penal Code (RPC), as amended by Republic Act (RA) 8353, in connection with aspects of RA 7610; and
One count of child abuse under Section 10(a) of RA 7610.

On May 2, 2009, at the residence of his niece where he practiced as a quack doctor, the accused allegedly guided AAA—a 16-year-old minor—into a private room, removing her shorts and underwear, and inserting his penis into her vagina under the claim that it would cure her epilepsy.
On May 4, 2009, a similar incident purportedly occurred when AAA returned for another session; the accused again removed the victim's clothes and proceeded with the sexual act, reiterating his unorthodox treatment method.
On May 6, 2009, the same sequence of unwelcome sexual intercourse was repeated with AAA.
On May 13, 2009, AAA expressed her unwillingness to continue the treatment to her mother, who, upon discovering the abuse, confronted the accused leading to his eventual arrest.
On May 14, 2009, a medico-legal examination by Dr. Lolita Hamoy corroborated AAA’s account, noting her vaginal canal admitted two fingers easily and that her hymen was no longer intact.

AAA, though a minor and described as being deprived of reason due to mental disability, provided a consistent and credible narrative of the abuse.
The evidence included her clear description of events, physical pain experienced, and the supportive findings of a medical examination indicating physical evidence of rape.

The accused, aged 87 at the time, admitted to treating AAA for her epilepsy using herbal remedies but denied the sexual abuse allegations.
He contended that the charges were fabricated by AAA’s mother, thereby attempting to explain the presence of personal familiarity and the alleged treatment relationship.

Despite AAA’s acknowledged mental disability, the trial court found her testimony clear and corroborated by medical findings.
The RTC convicted the accused for two counts of rape, considering his advanced age only as a mitigating circumstance, and imposed the penalty of reclusion perpetua.
The court declared that the accused’s advanced age did not preclude the possibility of sexual intercourse and ruled that his actions demonstrated fraudulent machination and grave abuse of authority.
It also awarded civil indemnity, moral damages, and exemplary damages at P100,000.00 each.

The Court of Appeals confirmed the conviction, though it reduced the damages awards to P75,000.00 each.
The appellate decision also noted the need to correct the designation of the offenses by deleting the improper correlation to RA 7610 while recognizing the appropriate charge under Article 266-A in relation to Article 266-B of the RPC.

Whether the prosecution’s evidence, comprising AAA’s consistent testimony and the medical findings, legally established the elements of rape beyond reasonable doubt.
Whether the accused’s defenses of denial and alibi were credible enough to cast doubt on the prosecution’s case.

Whether the alleged acts should be classified as rape under Article 266-A alone or as qualified rape within the ambit of Article 266-A in relation to Article 266-B of the RPC.
Whether the modification by the CA in deleting the correlation of the offense to RA 7610 was proper, given that the evidentiary basis indicated a crime of qualified rape due to the victim’s mental disability.

Whether the imposition of reclusion perpetua without eligibility for parole was justified in light of the special aggravating circumstances, specifically the accused’s knowledge of AAA’s mental disability.
Whether the award of damages should be adjusted in accordance with the qualifying circumstances present in the case.