Title
People vs. Ansano y Calleja
Case
G.R. No. 232455
Decision Date
Dec 2, 2020
Accused acquitted of raping a minor due to unreliable identification; Supreme Court found reasonable doubt in prosecution's evidence, emphasizing presumption of innocence.

Case Summary (G.R. No. 232455)

Procedural History and Key Dates

  • Alleged commission of the offense: April 6, 2005.
  • Medical examination: April 7, 2005 (medico-legal report).
  • RTC decision convicting accused: November 16, 2015.
  • CA decision affirming conviction with modification: February 20, 2017.
  • Supreme Court decision reversing and acquitting: December 2, 2020.
  • Applicable constitutional framework: 1987 Constitution (Article III, Section 14[2] on presumption of innocence) as the case decision date is after 1990.

Charged Offense and Information

The Information charged the accused with rape under Article 266-A of the Revised Penal Code, as amended by Republic Act No. 8353, alleging that on or about April 6, 2005 in XXX, ZZZ, the accused, while armed with a bolo and by force and intimidation, had carnal knowledge of AAA, a minor, against her will.

Facts as Found by the Prosecution (Witness AAA)

  • AAA testified that on April 6, 2005 at about 5:00 p.m. she was en route to fetch her father near Narra by the river when an unknown man (later identified as the accused) threatened her with a bolo and compelled her to go to a falls and then to a secluded area of bamboo and coconuts.
  • She described that the accused held her by the shoulder, told her to sit and not shout, undressed her, forced oral copulation (she vomited), and thereafter had vaginal intercourse twice, causing pain. He then dressed and left, warning her not to tell anyone.
  • She reported the incident to her parents and underwent a medico-legal examination at ZZZ Provincial Hospital. In court she identified the accused as the perpetrator, stating that she first “recognized” him during a drinking spree in their house on March 19, 2006, and later identified him from a photograph shown at the municipal hall/police station.
  • On her age: AAA testified she was thirteen years old at the time of the incident and presented a Certificate of Baptism (born September 14, 1991) as evidence; the Information, however, alleged she was fifteen.

Medical Evidence

Dr. Maria Cheryl Obcemea conducted the medico-legal examination on April 7, 2005 and prepared a Medico-Legal Report that recorded multiple fresh lacerations of the hymen at 7 and 5 o’clock positions with minimal bleeding — findings consistent with sexual assault.

Defense Case: Denial and Alibi

  • The accused testified denying knowledge of AAA and denying commission of the offense. He claimed an alibi: that on April 6, 2005 he was at Villa Pokan with friends Rudy Monfero, Albert Concordia and Nick Esmejarda to swim, arriving at about 4:00 p.m. and leaving about 5:00 p.m., then went home and slept, rising the next day.
  • Defense counsel manifested in court that the accused had no scar on his face when he testified; the prosecution suggested any scar claimed by AAA might have healed in the intervening years.

RTC Decision (November 16, 2015)

The RTC found AAA’s testimony credible, clear, consistent, spontaneous and unrelenting, and held that the medico-legal findings corroborated the assault. The RTC convicted the accused of rape under Article 266‑A, sentenced him to reclusion perpetua, and awarded civil, moral and exemplary damages totalling P130,000.

Court of Appeals Decision (February 20, 2017)

The CA affirmed the RTC’s findings but modified the award of damages. The CA emphasized AAA’s positive identification of the accused, the clarity and spontaneity of her testimony, and the medico-legal corroboration of assault. The CA also held that the accused’s alibi lacked probative value in light of AAA’s identification and therefore sustained the conviction.

Issue before the Supreme Court

Whether the RTC and CA erred in convicting the accused-appellant — specifically, whether the prosecution proved beyond reasonable doubt the identity of the accused as the perpetrator.

Governing Legal Principles on Burden of Proof and Identification

  • The Court reaffirmed the constitutional presumption of innocence (1987 Constitution, Art. III, Sec. 14[2]) and the principle that conviction must rest on the strength of the prosecution’s evidence, not on the weakness of the defense. The prosecution must establish beyond reasonable doubt both the commission of the crime and the identity of the accused as the offender.
  • In rape cases where identification may depend on a single witness, caution and strict scrutiny are required. The Court applied the “totality of circumstances” test (derived from Neil v. Biggers and Manson v. Brathwaite and adopted in local jurisprudence such as People v. Teehankee) to assess the reliability of out‑of‑court identifications. The test considers: (1) the witness’s opportunity to view the perpetrator, (2) degree of attention, (3) accuracy of prior description, (4) level of certainty during identification, (5) time between the crime and identification, and (6) suggestiveness of the identification procedure. Related local decisions (e.g., People v. Pineda, People v. Rodrigo, People v. NuAez) inform additional cautions about photographic identification, suggestiveness, memory fallibility, and the risk of wrongful identification.

Application of the Totality of Circumstances to the Case — Opportunity and Attention

  • The Court acknowledged that AAA had a reasonable opportunity to view her assailant during a prolonged close encounter in daylight and that her attention to the assailant would likely have been high given the violent nature of the assault. These two factors weighed in favor of possible reliable perception.

Application — Accuracy of Prior Description

  • AAA’s contemporaneous descriptions were limited and largely concerned clothing and that the assailant carried a bolo. Facial feature descriptions (scar, “butil‑butil” on the face, moustache, “medyo singkit”) emerged only later when she purportedly saw the accused in March 2006. The Court observed that those later identifiers did not reliably match the accused when the defense showed that the accused had no facial scar at the time of testimony. Because material facial descriptors were not contemporaneously recorded, this factor undermined the reliability of the identification.

Application — Time Lapse Between Crime and Identification

  • A significant time lapse existed: the assault occurred in April 2005, the first purported recognition in a drinking spree was in March 2006 (almost one year later), and the definitive photographic identification occurred around May 2006. The Court noted jurisprudence recognizing that longer retention intervals diminish the accuracy and completeness of eyewitness accounts, and the roughly one‑year lapse here weighed against reliability.

Application — Level of Certainty and Suggestiveness of Identification Procedure

  • AAA initially described her March 19, 2006 reaction as “namumukhaan” (having a feeling of resemblance/recognition), not a definite identification. She later examined a photograph at the municipal hall/police station and stated she was “sure” after seeing the photo. The record shows she was shown a single photograph (not a proper array of photographs), and that BBB (the niece who had the separate case) was

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