Case Summary (G.R. No. 246146)
Key Dates
• Incident: August 30, 2012.
• RTC Decision: June 2, 2017.
• CA Decision: September 27, 2018.
• CA Resolution: March 4, 2019.
• SC Decision: March 18, 2021.
Applicable Law
• 1987 Constitution (as decision is post-1990).
• Revised Penal Code, Article 336 (Acts of Lasciviousness).
• Republic Act No. 7610, Section 5(b) (Lascivious Conduct on Minors).
• Republic Act No. 9344 (Juvenile Justice and Welfare Act).
• Indeterminate Sentence Law.
• Jurisprudence on factual review, witness credibility, women’s honor doctrine, alibi and denial defenses.
Factual Antecedents
AAA was inside her school campus when petitioner allegedly grabbed her, threatened her with an icepick, kissed her lips and neck, removed her garments, and groped her breasts against her will. AAA escaped when a teacher passed, later reported the assault to a priest, her aunt, school authorities, the barangay, and finally to the police.
Defense Position
Petitioner denied the allegations, presenting an alibi that he was in MAPEH class from 6:45 PM to 8:00 PM, supported by testimony from his teacher FFF and classmates CCC and DDD. He claimed to have gone home by 8:30 PM.
RTC Ruling
The RTC found petitioner guilty beyond reasonable doubt of Acts of Lasciviousness (Article 336 RPC), imposed 20 days of arresto menor, awarded AAA ₱20,000 civil indemnity, ₱30,000 moral damages, and ₱2,000 exemplary damages, and suspended sentence under R.A. 9344 due to petitioner’s minority.
CA Ruling
The Court of Appeals affirmed the RTC conviction and damages award, rejecting petitioner’s challenge to witness credibility and his alibi defense.
Issue on Appeal
Whether the CA erred in upholding petitioner’s conviction for Acts of Lasciviousness despite alleged inconsistencies in AAA’s testimony and uncontroverted alibi evidence.
Standard of Review
Factual findings, especially on credibility, carry great weight when made by the trial court and affirmed by the CA. The Supreme Court will not disturb such findings absent misapprehension of material facts.
Credibility of Complainant
The Court upheld the clear, positive, and consistent testimony of AAA as intrinsically believable. Minor discrepancies regarding the school’s population and timeline were deemed immaterial to the core narrative.
Women’s Honor Doctrine
The Supreme Court confirmed that the tempered women’s honor doctrine permits conviction on the victim’s credible testimony alone, particularly for young and vulnerable complainants, without reverting to outdated cultural stereotypes.
Defense of Denial and Alibi
Denial is weak unless supported by strong evidence; alibi must prove physical impossibility. Petitioner failed to demonstrate such impossibility given spatial and temporal proximity. Lower courts properly rejected his defense.
Modification of Crime Designation
The Supreme Court reclassified the offense as Lascivious Conduct under Section 5(b) of R.A. 7610, given that the victim was under 18 years old, aligning with current jurisprudence on sexual offenses against minors.
Modification of Penalty
Recognizing petitioner’s minority as a mitigating circumstance, the penalty was adjusted to prision correccional medium (2 years, 4 months, 1 day
...continue readingCase Syllabus (G.R. No. 246146)
Facts
- On August 30, 2012, at about 7:45 PM in Quezon City, 15-year-old AAA was on campus when CICL XXX, also 15, allegedly grabbed her, pointed an icepick at her, forced kisses from her lips to her neck, unbuttoned her blouse, removed her undergarments, and mashed her breasts without consent.
- AAA escaped when a teacher passed by, returned home, then a week later confided in a priest and reported the incident to her aunt, the school authorities, the barangay office, and finally the Women’s Desk of Batasan Hills Police Station.
Defense Version
- CICL XXX denied wrongdoing and asserted an alibi: he was in MAPEH class from 6:45 PM to 8:00 PM with about 50 classmates; he left school at 8:00 PM, arrived home by 8:30 PM; no motive or grudge existed against AAA or her family.
Trial Court Decision (RTC)
- RTC–Q.C., Branch 94, found petitioner guilty beyond reasonable doubt of Acts of Lasciviousness (RPC Article 336).
- Sentence imposed: 20 days of arresto menor (suspended due to minority).
- Damages awarded: ₱20,000 civil indemnity; ₱30,000 moral damages; ₱2,000 exemplary damages; 6% interest per annum from finality.
Court of Appeals Ruling
- CA in CA-G.R. CR No. 40165 affirmed the RTC decision on September 27, 2018.
- Denied petitioner’s motion for reconsideration on March 4, 2019.
- Petitioner’s sole ground: prosecution evidence allegedly insufficient to prove guilt beyond reasonable doubt.
Issue
- Whether the Court of App