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)

Factual Background

On the evening of March 25, 2004, AAA, a 16-year-old minor, attended a graduation dinner and thereafter was lured into a drinking session at Alsonas Palace. Despite her initial refusal, she consumed multiple shots of brandy until she lost full consciousness. She was then carried to Alquizola Lodging House, where Carampatana and Oporto took turns having non-consensual sexual intercourse with her while Alquizola kissed and watched. AAA awoke intermittently, resisted, and cried in pain. By dawn she was alone, partially undressed, and visibly injured. She reported the incident, underwent medical examination (revealing old hymenal laceration and sperm in vaginal smear), and formally accused the respondents of rape.

Trial Court Decision

On February 28, 2006, the RTC convicted Carampatana and Oporto of rape and Alquizola as accomplice. Carampatana received reclusion perpetua; Oporto prision mayor (6 years, 1 day to 12 years); Alquizola an indeterminate term. Civil indemnity, moral and exemplary damages, attorney’s fees, and costs were awarded. Five co-accused were acquitted for lack of proof.

Court of Appeals Decision

On June 6, 2008, the CA reversed and set aside the RTC verdict, acquitting Carampatana, Oporto, and Alquizola. It held that AAA consented, was conscious throughout, showed no physical resistance, and that medical findings of an old hymenal tear suggested prior sexual activity. The CA also noted AAA’s mother struck her in anger—a reaction more consistent with premarital sex than rape.

Petition for Certiorari and Raised Issues

AAA filed a Rule 65 petition alleging the CA acted with grave abuse of discretion in acquitting the respondents. The respondents argued (1) acquittals are final and not appealable; (2) no grave abuse; (3) a motion for reconsideration was required; and (4) only the Solicitor General could prosecute criminal appeals. The OSG filed a separate comment supporting reversal on grounds of grave abuse and civil-aspect appealability.

Appeal of Acquittal and Standing

Under Section 21, Article III, 1987 Constitution, a judgment of acquittal is final and bars prosecution appeal except on civil aspects or by certiorari upon grave abuse of discretion. The private offended party may file a certiorari petition in her own name when alleging jurisdictional infirmity. AAA, as aggrieved by the CA’s decision, had legal standing; the OSG’s joinder satisfied prosecutorial direction requirements.

Exception to Motion for Reconsideration

Although ordinarily a motion for reconsideration precedes certiorari, exceptions include questions already passed upon, patent nullity, and urgencies. AAA raised the same factual and legal issues before the CA, there was urgency to vindicate her rights, and the CA’s reversal was a patent nullity for lack of due process and grave abuse of discretion.

Grave Abuse of Discretion Standard

Grave abuse of discretion is a capricious or whimsical exercise of judgment equivalent to jurisdictional lack. It arises when a court ignores positive duty, fails to consider vital evidence, or acts arbitrarily, thereby denying due process and causing injustice.

Appellate Court’s Disregard of Prosecution Evidence

The CA’s fact narrative mirrored exclusively the respondents’ testimonies and largely ignored AAA’s credible account and the RTC’s findings. By crediting only defense evidence and casting aside prosecution proofs, the CA violated due process and committed grave abuse of discretion.

Victim’s Intoxication and Elements of Rape

Under Article 266-A RPC, rape is carnal knowledge (1) by force or intimidation, (2) when the victim is deprived of reason or unconscious, (3) by fraudulent machination or abuse of authority, or (4) under twelve years of age. Here, respondents deliberately intoxicated AAA until she was unconscious, then had intercourse repeatedly. Her incapacity negated any valid consent.

Credibility of the Victim’s Testimony

Victim testimony alone, if credible, suffices for rape conviction. The RTC found AAA’s testimony simple, candid, and unrehearsed despite the trauma and public trial. The CA offered no reason to discredit her, undermining a core principle that due process demands consideration of all evidence.

Burden Shift on Consent Defense

When an accused asserts consensual intercourse, the burden shifts to him to present convincing proof (e.g., love letters, credible witnesses) of a genuine relationship. Respondents admitted carnal acts yet produced no evidence of consent or prior romantic involvement, failing to meet this burden.

Medical Findings and Hymenal Laceration

The CA’s emphasis on an old hymenal tear misconstrued medical law: a fresh laceration is not an essential element of rape and consensual lubrication does not preclude injury. The presence of an old tear did not establish prior consent or negate the crime, especially given AAA’s intoxication.

Mother’s Reaction and Complainant’s Credibility

AAA’s mother striking her upon learning of the assault does not negate rape. Human reactions under emotional stress vary widely. In the absence of improper motive by AAA, her prompt report

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