Case Summary (G.R. No. 250934)
Applicable Law
The case concerns the Revised Penal Code of the Philippines, specifically Article 266-A on the crime of rape, as amended by Republic Act No. 8353 and in relation to Republic Act No. 7610, which protects children against abuse, exploitation, and discrimination.
Facts of the Case
On June 17, 2011, Melford Brillo y De Guzman was charged with rape under Article 266-A for an incident occurring on October 1, 2010. The indictment states that Brillo, using force and intimidation, had sexual intercourse with "AAA" while she was intoxicated. The prosecution's evidence detailed that after attending a drinking spree, AAA became dizzy and passed out, only to wake up later to find Brillo on top of her, having sexual intercourse with her against her will.
Prosecution's Evidence
The prosecution presented AAA's testimony, detailing the events leading up to the rape, including how she was pressured to drink alcohol and subsequently lost consciousness. Additional corroboration came from a medico-legal examination performed by Dr. Rolando Marfel Ortiz, which confirmed physical signs of sexual assault, including vaginal lacerations.
Defense's Argument
The defense relied solely on Brillo's testimony, denying any wrongdoing. Brillo claimed that he distanced himself from AAA during the drinking session and presented a narrative that contradicted the prosecution’s version of events. He asserted that AAA initiated contact with him in a manner that implied consent, and he distanced himself from the encounter.
RTC Ruling
The RTC delivered its judgment on November 21, 2017, convicting Brillo of rape, emphasizing that AAA was too intoxicated to consent. The court found AAA's testimony credible and compelling, which was supported by the medical evidence indicating lacerations consistent with sexual assault. Brillo was sentenced to reclusion perpetua and ordered to pay damages.
CA Ruling
Brillo appealed to the CA, challenging both the credibility of AAA's testimony and the sufficiency of the evidence against him. However, on March 1, 2019, the CA upheld the RTC's ruling, affirming the conviction and modifying the monetary damages awarded to AAA, increasing them to P75,000 for civil indemnity, moral damages, and exemplary damages.
Court's Ruling
The Supreme Court upheld the conviction, noting the difficulty inherent in a "he said, she said" scenario. The court reaffirmed that AAA's intoxication rendered her unable to consent, fulfilling the criteria for rape under the law. The credibility of witnesses is paramount, and the trial court's findings merit respect unless clearly errant. The Court emphasized that the prosecution had established all ele
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Case Background
- Case Citation: G.R. No. 250934, June 16, 2021.
- Parties Involved: People of the Philippines (Plaintiff-Appellee) vs. Melford Brillo y De Guzman (Accused-Appellant).
- Judicial Authority: Third Division of the Supreme Court of the Philippines.
- Initial Ruling: The appeal assails the March 1, 2019 Decision of the Court of Appeals (CA) affirming with modifications the November 21, 2017 Judgment of the Regional Trial Court (RTC) of Olongapo City, which convicted the accused-appellant of rape.
Statement of Facts
- Indictment: On June 17, 2011, Melford Brillo y De Guzman was indicted for the crime of Rape under Article 266-A, par. 1(b) of the Revised Penal Code, as amended by RA 8353, in relation to RA 7610.
- Details of the Incident: The alleged crime occurred on October 1, 2010, involving a 15-year-old minor, referred to as “AAA.” The prosecution claimed that the accused-appellant engaged in sexual intercourse with AAA against her will, using force and taking advantage of her intoxication.
- Circumstances Leading to the Crime:
- AAA was at a drinking party with friends, where she was coerced into drinking alcohol.
- After becoming dizzy and passing out, AAA awoke to find the accused-appellant sexually assaulting her.
- The incident was witnessed by several individuals who were present during the party.
Evidence Presented
Prosecution Evidence
- Testimony of AAA: Described being forced to drink alcohol and later finding herself naked with the accused-appellant on top of her. She attempted to resist but was physically overpowered.
- Medical Examination: Conducted by Dr. Rolando Marfel Ortiz, who documented lacerations consistent with sexual assault.
- Witnesses: The prosecution established the presence of other individuals during the incident, who wer