Case Summary (G.R. No. 181571)
Charges and Background
BBB was charged under Article 266-A(2) of the Revised Penal Code concerning allegations made on November 14, 2012. The complaint stated that BBB inserted his finger into AAA's vagina against her will, an act classified as rape by sexual assault. BBB pleaded not guilty upon arraignment.
Prosecution's Version
The complainant, AAA, testified about the events leading to the alleged assault. After being invited to a friend’s home during a school event, BBB isolated her by asking her friend to leave. Subsequently, BBB inquired about her menstrual cycle, initiated physical contact, and assaulted her. Following the incident, AAA reported the matter to her class advisor, leading to a medical examination, where signs of trauma were discovered by Dr. Ureta.
Defense's Argument
BBB contended that he was only fifteen years old and argued he was in a consensual relationship with AAA. He admitted to seeing her that day but characterized the circumstances differently, claiming he did not engage in any lewd actions. His defense relied largely on the assertion that AAA had no motive to claim he harmed her.
Trial Court's Ruling
The Regional Trial Court (RTC) convicted BBB of sexual assault, determining that while the medical examinations did not confirm rape, the act constituted lascivious conduct towards a minor. He received an indeterminate sentence along with monetary damages to be paid to the victim. The RTC acknowledged AAA's credible testimony and the findings of the social worker, establishing that BBB acted with discernment.
Court of Appeals Decision
The Court of Appeals upheld the RTC's ruling but highlighted the discrepancy within the RTC's decision regarding the classification of BBB’s actions. The appellate court affirmed that despite the lack of hymenal rupture, the actions constituted rape by sexual assault due to AAA's age and BBB's discernment.
Present Petition
BBB sought review, claiming the Court of Appeals erred in its factual findings and the imposition of the penalty under RA 7610. He argued that both he and AAA were minors and that the application of the stricter law was inappropriate in this context. The People countered, asserting that BBB's appeal raised factual issues inappropriate for a certiorari petition.
Issues
Two key issues were raised:
- Whether the Court of Appeals erred in finding BBB guilty of rape by sexual assault.
- Whether the application of the penalty under RA 7610 was appropriate, given BBB's status as a minor.
Court's Ruling on the Merits
The court recognized the preference to respect the trial court’s factual findings, primarily revolving around credibility. The prosecution presented credible evidence through AAA’s coherent and consistent testimony, corroborated by medical findings. The court ruled that a minor’s testimony, particularly in sexual assault cases, generally carries significant weight, solidifying the conviction.
Applicability of Penalties
The court examined the implications of applying RA 7610's penalties versus those established under the Revised Penal Code. It sided with the notion that RA 7610 is aimed primarily
...continue readingCase Syllabus (G.R. No. 181571)
The Case
- This case involves a petition for review on certiorari seeking to reverse the Decision dated August 29, 2019, of the Court of Appeals in CA-G.R. CR No. 01722-MIN.
- The Court of Appeals affirmed with modification the conviction of petitioner BBB for rape by sexual assault.
Antecedents
- Petitioner BBB was charged with rape by sexual assault under Article 266-A (2) of the Revised Penal Code (RPC) in relation to Republic Act No. 7610 (RA 7610).
- The charge stemmed from an incident on November 14, 2012, in North Cotabato, Philippines, where it was alleged that BBB, using force and intimidation, inserted his finger into the genitalia of 11-year-old AAA against her will.
- The information stated that this act debased, degraded, and demeaned the intrinsic worth and dignity of AAA as a child.
Version of the Prosecution
- AAA testified that on November 14, 2012, she was invited by her classmate to Socubos' house, where she was left alone with BBB.
- BBB asked her if she had her monthly period, then proceeded to undress her and kissed her before inserting his finger into her vagina, causing her pain.
- After the incident, AAA fled to school, and eventually, the matter was reported to her mother and the authorities where she underwent a medical examination revealing signs of past trauma.
Version of the Defense
- BBB, who was 15 years old at the time, claimed he and AAA were in a relationship.
- He stated that he was at Socubos' house to compose a song, and when AAA and her classmate entered, they were alone but he did not engage in any inappropriate conduct.
- BBB denied the