Case Summary (G.R. No. 231358)
Factual Antecedents
Ernesto Avelino was formally charged with rape under Republic Act No. 7610, with the specifics outlined in an Information alleging that in May 2006, he unlawfully had carnal knowledge of AAA, a mentally challenged minor aged 15, through violence, threats, and intimidation. Avelino entered a plea of not guilty during his arraignment on September 5, 2007. At a pre-trial, the parties stipulated to several points, including the jurisdiction of the court and AAA's minority status.
Prosecution's Version
The prosecution's narrative, derived from AAA's testimony, outlined a series of events where AAA, while babysitting Avelino's son, was threatened with a knife by Avelino, who then forcibly undressed her and raped her. AAA reported the incident only after becoming pregnant, leading to formal complaints and a police investigation. Medical examinations subsequently confirmed injuries consistent with sexual assault.
Defense's Version
Avelino's defense rested on the denial of the allegations, asserting no personal knowledge of AAA and claiming he was with his family on the day of the alleged incident. His father corroborated his testimony, further disputing the prosecution's claims by suggesting AAA and her family were merely tenants separated by a wall, which he maintained was not conducive to the alleged incident.
Ruling of the Regional Trial Court
On May 28, 2015, the Regional Trial Court (RTC) of Caloocan City found Avelino guilty of rape, deeming AAA's testimony credible against the denials presented by the defense. The court's ruling emphasized the prosecution's fulfillment of the evidentiary burden, establishing the essential elements of rape, leading to Avelino being sentenced to reclusion perpetua along with civil indemnity and damages.
Ruling of the Court of Appeals
The Court of Appeals (CA) affirmed the RTC decision on August 31, 2016, albeit with a modification regarding the damages awarded. The appellate court emphasized the credibility of AAA's testimony and dismissed the appeal, asserting that Avelino's defense of alibi and denial did not outweigh the compelling evidence presented by the prosecution.
Issue on Appeal
The central issue in Avelino's appeal was whether he was guilty of rape. He contended that the RTC erred in ascribing credibility to AAA's testimony, dismissing his defense's inconsistencies, and incorrectly sentencing him under provisions that he argued should be linked to RA 7610.
Our Ruling
Upon comprehensive review, the Court found Avelino's appeal lacking merit. Both the RTC and CA substantiated the prosecution's evidence, confirming that Avelino had forcefully raped AAA, which satisfied the legal definitions of the crime under the Revised Penal Code. The Court upheld the idea that the
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Case Information
- Court: Supreme Court of the Philippines, First Division
- G.R. No.: 231358
- Date of Decision: July 08, 2019
- Parties:
- Plaintiff-Appellee: People of the Philippines
- Accused-Appellant: Ernesto Avelino, Jr. y Gracillian
Procedural History
- The accused-appellant, Ernesto Avelino, Jr. y Gracillian, contested the August 31, 2016 Decision of the Court of Appeals (CA) in CA-G.R CR HC No. 07543.
- The CA affirmed with modification the May 28, 2015 Decision of the Regional Trial Court (RTC) of Caloocan City, which found him guilty of rape.
Factual Antecedents
- Charge: Rape under Republic Act (RA) No. 7610.
- Incident Date: May 2006, in Caloocan City.
- Victim: AAA, a 15-year-old mental retardate.
- Accusation Details: The Information stated that Avelino, with lewd design and by means of force, threats, and intimidation, had carnal knowledge of AAA against her will and without her consent.
Arraignment and Pre-Trial
- Appellant pleaded not guilty during the arraignment on September 5, 2007.
- During pre-trial, stipulations were made regarding the trial court's jurisdiction, the identity of the appellant, the victim's minor status, and the existence of the medico-legal certificate.
Version of the Prosecution
- Testimonies Presented:
- AAA's account of the incident, supported by Police Chief Inspector Jesille Cui Baluyot's testimony regarding the medico-legal findings.
- Incident Description:
- AAA was babysitting Avelino's son when Avelino, armed with a knife, threatened her.
- Avelino undressed AAA against her will and raped her, while threatening her not to disclose the incident.
- The incident was reported only after AAA became pregnant, leading to the police filing a complaint.