G.R. No. 252865 - People vs. YYY

The case involves accused-appellant YYY, charged with multiple counts of Statutory Rape alleged to have been committed on January 24, 25, and 26, 2007 in Camarines Sur, Philippines.
The charges arise from five separate Informations (Criminal Case Nos. 09-1411 to 09-1415) filed before the Regional Trial Court (RTC), with one count later acquitted by the RTC.
Arraignment of accused-appellant took place on August 25, 2009, where he pleaded not guilty to all charges.
The RTC rendered its Decision on February 13, 2018, convicting YYY beyond reasonable doubt in four counts of Statutory Rape and acquitting him in one count where the testimony was inconsistent.

Accused-appellant allegedly entered a household where two minor victims, AAA (2 years old) and BBB (8 years old), were present.
He is alleged to have removed his clothes and BBB’s shorts and panty, placed himself on top of BBB, and inserted his penis into her vagina.
Subsequently, he proceeded to AAA, undressed her and similarly attempted sexual penetration.

While the victims’ parents were away, accused-appellant reportedly broke into their house.
He allegedly undressed BBB and again attempted to rape her, spreading her legs and attempting penetration.
BBB resisted by kicking him, although the assault continued to be attempted on AAA immediately after.

Further allegations state that BBB, while at accused-appellant’s house looking for his mother, was forcibly pushed inside.
He allegedly removed her shorts and panty, spread her legs, and attempted another act of sexual penetration, which was again thwarted by her resistance.

Victim AAA later informed her mother about the incidents, and both victims testified, identifying YYY as the perpetrator.
The medico-legal reports, despite revealing no recent extragenital injury or damage to the hymen, were regarded as corroborative rather than conclusive evidence.

The testimonies of the victims, AAA and BBB, were clear, simple, and spontaneous.
The RTC gave full credit to these testimonies, noting that the youth and immaturity of the victims often serve as badges of truth.
Witnesses, including family members, were called, but none corroborated the defense’s claim regarding the accused’s minority.
The birth certificates of AAA and BBB were submitted and admitted without contest, firmly establishing their ages at the time of the incidents.

The RTC found accused-appellant guilty on four counts (three counts relating to BBB and one count pertaining to AAA, later reclassified as Qualified Statutory Rape) and ordered reclusion perpetua along with specific monetary damages.
The Court of Appeals (CA) affirmed the RTC’s decision with modification, particularly in the award of damages.
Accused-appellant raised arguments based on his claim of minority, insufficiency of evidence, and a defense of denial, which were ultimately rejected in both the RTC and CA rulings.

Whether the CA erred in affirming the conviction of accused-appellant despite his claim of minority and alleged insufficiency of evidence.

The argument centered on whether YYY’s claim of being 17 years old at the time of the commission of the crimes merited a reconsideration of his guilt.
Whether the defense’s reliance on testimonial evidence regarding the accused’s age, without documentary support, should have influenced the Court’s findings.

Whether the cumulative evidences—specifically the eyewitness testimonies of the minor victims—were sufficient to support a conviction for Statutory Rape and, in one instance, Qualified Statutory Rape.

The reliability of the victim testimonies as opposed to the uncorroborated alibi provided by accused-appellant.
Whether the absence of corroborative physical injuries (as per the medico-legal reports) could undermine the victims’ consistent and credible accounts.

Whether the defense’s alibi and denial, on the basis of alleged employment as a store helper, adequately refuted the identification and the proximity of YYY to the crime scene.