Title
People vs. Court of Appeals
Case
G.R. No. 183652
Decision Date
Feb 25, 2015
A 16-year-old minor, intoxicated and unconscious, was sexually assaulted by three men. Despite initial acquittal, the Supreme Court reversed, convicting them of rape, citing lack of consent and credible testimony.

Case Summary (G.R. No. 183652)

Procedural Posture and Relief Sought

AAA sought relief by filing a petition for certiorari under Rule 65 of the Rules of Court to challenge the Court of Appeals (CA) decision which reversed the Regional Trial Court (RTC) conviction and acquitted the private respondents of rape. The petition alleged that the CA acted with grave abuse of discretion amounting to lack or excess of jurisdiction. The OSG filed a supporting comment; the private respondents opposed the petition and raised issues including double jeopardy and procedural prerequisites.

Facts as Found at Trial

On March 25–26, 2004, AAA attended graduation-related festivities, drank hard liquor in a group setting and, according to her testimony, was made to consume repeated shots of Emperador Brandy until intoxicated and unconscious at intervals. She testified she later regained partial consciousness at the Alquizola Lodging House and was sexually assaulted repeatedly by Oporto and Carampatana while Alquizola watched and kissed her; she also testified to being carried down stairs and transported between premises. Medical examination disclosed an old hymenal laceration at 5 o’clock and hyperemia of the posterior fornices; a vaginal smear revealed presence of sperm. The defense presented an alternative version claiming consensual sexual activity and denied forcible rape.

Charges and Trial Court Disposition

Private respondents were charged by Second Amended Information with rape (alleging forceful intoxication then carnal knowledge against the will of AAA). At trial, the RTC credited AAA’s testimony and related evidence, found the private respondents guilty beyond reasonable doubt (with differing penalties and civil damages for each), and acquitted several co‑accused for insufficiency of proof. The RTC concluded AAA was credible, was intoxicated/unconscious during material acts, and that the defense’s claim of consent was belated and unproven.

Court of Appeals Decision and Grounds for Acquittal

The CA reversed and set aside the RTC conviction, acquitting the private respondents for lack of proof beyond reasonable doubt. The CA credited the defense version, emphasizing that AAA allegedly remained conscious and did not physically resist, did not shout for help, and had an old hymenal laceration suggesting prior sexual experience. The CA further considered the mother’s reaction as more consistent with discovery of premarital sex than with sexual assault. On those bases, the CA found the prosecution failed to negate consent.

Issues Presented on Certiorari and Preliminary Procedural Questions

The sole issue presented by AAA was whether the CA acted with grave abuse of discretion in acquitting the respondents. Procedural questions addressed by the Supreme Court included (1) whether AAA could file the certiorari petition despite the general bar on the prosecution appealing acquittals (double jeopardy), (2) whether a prior motion for reconsideration was required, and (3) whether the OSG should have filed or joined the petition. The Court applied a liberal construction of procedural rules to secure substantial justice and considered exceptions to strict prerequisites where appropriate.

Standing, Double Jeopardy, and Rule 65 Remedy

The Court held that an aggrieved private offended party may file a special civil action for certiorari in her own name to challenge an acquittal on jurisdictional grounds (grave abuse of discretion), particularly when the petition raises the same issues passed upon by the lower courts and when the OSG joins the cause. Section 21, Article III of the 1987 Constitution was cited to explain the bar on appeals by the prosecution, but the exception—Rule 65 when grave abuse is shown—permits the Court to act without violating double jeopardy. The OSG’s later joinder satisfied the requirement that criminal actions be prosecuted under the direction and control of the public prosecutor.

Motion for Reconsideration Requirement and Its Exception

Although a motion for reconsideration is ordinarily a precondition to a Rule 65 petition, the Court recognized established exceptions (including when the issues raised were already passed upon below and where delay would prejudice interests). AAA’s petition fit exceptions: it raised issues already litigated and invoked urgent interests; the Court also found the CA decision to be a patent nullity for lack of due process and grave abuse of discretion, justifying bypass of a motion for reconsideration.

Standard of Grave Abuse of Discretion and Application to CA Findings

The Court reiterated that grave abuse of discretion exists when a tribunal acts capriciously, arbitrarily, or in a manner equivalent to lack of jurisdiction. It found that the CA committed grave abuse by selectively adopting the defense account and by disregarding or downplaying material prosecution evidence. The CA’s factual narrative closely mirrored the accused’s testimony and failed to explain why the victim’s testimony and the RTC’s credibility findings deserved little or no weight. The appellate court’s failure to consider the entire record and its apparent bias amounted to a deprivation of due process that rendered the acquittal tainted by grave abuse.

Evidentiary Weight of the Victim’s Testimony and Intoxication under Article 266‑A

The Court emphasized the well‑established principle that the uncorroborated testimony of a rape victim, if credible, may suffice for conviction. It upheld the RTC’s finding that AAA’s testimony was simple, candid and consistent with the circumstances, and that she was heavily intoxicated and repeatedly rendered unconscious—conditions covered by Article 266‑A(1)(b) (rape when the offended party is deprived of reason or otherwise unconscious). The CA’s reliance on absence of physical resistance and the presence of an old hymenal laceration did not negate the effect of intoxication in making valid consent impossible.

Medical Findings and Mother’s Conduct: Proper Weight and Misconceptions

The Court rejected the CA’s inferences from medical findings and parental reaction. It held that an old hymenal laceration is not dispositive on the issue of consent and is not an essential element to establish rape; penetration may occur without fresh hymenal rupture. Likewise, a parent’s physical reaction on learning of such an incident cannot be given fixed probative value to transform a rape allegation into mere premarital sex. The Court stressed that moral character or past sexual conduct of the victim does not preclude rape and that the totality of evidence must be assessed.

Burden Shift When Consent Is Asserted; Defense Failure to Prove Consent

Because the accused admitted carnal knowledge and later asserted consent, the Court recognized the evidentiary shift: the accused carried the affirmative duty to present convincing evidence of consensual relationship or consent (love notes, credible witnesses, or other corroboration). The private respondents failed to present substantial evidence to discharge this burden. Their claim of consensual intercourse was belatedly raised at trial and was contradicted by the circumstances (forceful intoxicati

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