G.R. No. 171348 - People vs. Erguiza

Case Summary (G.R. No. 171348)

Petitioner and Respondent

Petitioner: People of the Philippines (plaintiff‑appellee); Respondent/Accused‑Appellant: Larry Erguiza.

Key Dates

Alleged rape: January 5, 2000; Information filed: April 10, 2000; RTC decision convicting appellant: November 27, 2000; Court of Appeals decision affirming with modification: November 18, 2005; Supreme Court decision (review): November 26, 2008.

Applicable Law and Legal Standards

The case was decided under the 1987 Philippine Constitution (applicable because the Supreme Court decision date is post‑1990). The criminal charge was prosecuted under Article 266‑A, paragraph 1(a), in relation to Article 266‑B of R.A. No. 8353 (the Anti‑Rape Law as in effect), with ancillary references in the decisions to R.A. No. 7659 and relevant rules of evidence and procedure (Rules of Court, Rule 130 §24 on offers of compromise; Rule 133 §2 on reasonable doubt). Controlling evidentiary and doctrinal standards cited include proof beyond reasonable doubt (moral certainty), scrutiny of rape complainant testimony, the alibi standard (presence elsewhere and physical impossibility), and the equipoise rule (where evidence is equally balanced, benefit goes to accused).

Procedural History

An Information charging rape was filed and appellant pleaded not guilty. Trial ensued at the Regional Trial Court (RTC) of San Carlos City, Pangasinan, Branch 57. The RTC convicted and sentenced appellant to reclusion perpetua and ordered payment of civil indemnity, moral and exemplary damages, and support for the victim’s offspring. The Court of Appeals affirmed the conviction but modified the exemplary damages. Appellant sought review in the Supreme Court, which examined the record de novo on credibility and sufficiency of evidence.

Prosecution’s Version of Events

AAA testified that on January 5, 2000, at about 4:00–5:00 p.m., she, Joy and Ricky went to the mango orchard to gather mangoes; she was allegedly left behind when her shorts caught on a fence, and while unhooking them Larry suddenly grabbed her, showed a kitchen knife, dragged her to a tamarind tree, forcibly removed her clothing, forced sexual intercourse (penetration), threatened to kill her and her family if she spoke, and then fled. AAA later felt symptoms (absence of menses, palpitation) and, after consultation with a hilot, disclosed pregnancy and reported the incident to police on April 8, 2000. Dr. Sison’s medical exam noted a completely healed hymenal laceration at the 11:00 o’clock position and described the finding as suggestive, not conclusive, of rape; he indicated a DNA test for paternity.

Defense’s Version of Events

Appellant’s defense presented an alibi: appellant participated in house repairs in the morning and, at about 5:00 p.m., was sent to fetch a hilot (Juanita Angeles) because his wife was in labor; Juanita testified appellant fetched her at approximately 5:10 p.m., they arrived home about 5:30 p.m., and appellant remained with the hilot and wife until delivery at about 3:00 a.m. Albina Erguiza corroborated this timeline and denied that appellant left the house after fetching the hilot; Joy testified that she did not leave AAA when AAA’s shorts were hooked and that they went home together and parted at Aunt Beth’s store, directly contradicting AAA’s claim of being left alone. Juanito Macaraeg testified he did not see appellant in the orchard and described the short walking distance between the orchard and appellant’s house.

Trial Court Findings and Sentence

The RTC found appellant guilty of rape under the applicable provisions of R.A. No. 8353 and sentenced him to reclusion perpetua. The RTC also awarded P50,000 as civil indemnity, P50,000 as moral damages, P50,000 as exemplary damages, ordered support for AAA’s offspring, and imposed costs.

Court of Appeals Ruling

The Court of Appeals affirmed the RTC’s conviction but reduced exemplary damages to P25,000 while maintaining P50,000 for civil indemnity and moral damages, and upheld the order to provide support to AAA’s offspring.

Issues Raised on Appeal to the Supreme Court

Appellant argued (1) the trial court erred in crediting AAA’s testimony which appellant claimed was incredible, (2) the prosecution failed to prove guilt beyond reasonable doubt, and (3) the trial court failed to properly appreciate the alibi corroborated by defense witnesses.

Supreme Court’s Reassessment of Credibility and Evidentiary Sufficiency

The Supreme Court emphasized that, while trial court credibility findings are generally entitled to deference, they are not immune from reevaluation on appeal where material facts or circumstances were overlooked or misinterpreted. The Court examined the totality of testimonial and medical evidence, and found unrebutted testimony from defense witnesses (notably Joy and Juanita) that materially contradicted AAA’s account. The Court stressed the prosecution’s duty to present a persuasive case and to rebut defense evidence that critically undermines its theory.

Medical Evidence and Its Weight

Dr. Sison’s finding of a healed hymenal laceration at 11:00 o’clock was characterized by the doctor as suggestive, not conclusive, of rape; the doctor recommended DNA testing for paternity. The Supreme Court treated the medical finding as probative but insufficient, without corroborative and conclusive evidence, to satisfy the requirement of moral certainty as to appellant’s guilt.

Analysis of the Alleged Offer to Compromise

Conflicting accounts were presented concerning a monetary settlement. BBB and CCC claimed the appellant’s family offered money to settle; Albina denied this and asserted that BBB and CCC demanded money. The Court applied the principle that an offer of compromise by an unauthorized person cannot be imputed as an admission by the accused unless the accused was present or had authorized the offer. On the record, appellant denied authorizing any settlement and was not present when the alleged offer was made; accordingly the Court declined to treat the alleg

Case Syllabus (G.R. No. 171348)

Citation and Procedural Posture

G.R. No. 171348; Decision promulgated November 26, 2008; reported at 592 Phil. 363; Third Division; decision authored by Justice Austria‑Martinez.
Appeal from: Court of Appeals Decision dated November 18, 2005 in CA‑G.R. CR H.C. No. 00763 which affirmed with modification the Regional Trial Court (RTC) of San Carlos City, Pangasinan, Branch 57, Decision dated November 27, 2000 in Criminal Case No. SCC‑3282.
Criminal Information filed April 10, 2000: appellant charged with one count of rape allegedly committed on or about 5:00 o’clock in the afternoon of January 5, 2000, at the back of Bical Norte Elementary School, Bayambang, Pangasinan; victim identified in records as “AAA,” a 13‑year‑old minor; allegation included that the accused was armed with a kitchen knife and used force and intimidation.
Trial court (RTC) rendered conviction on November 27, 2000: found Larry C. Erguiza guilty of rape under Article 266‑A paragraph 1(a) in relation to Article 266‑B of R.A. 8353 and R.A. 7659; imposed reclusion perpetua and awarded civil indemnity, moral and exemplary damages and support to the victim’s offspring.
Court of Appeals affirmed RTC’s conviction but modified exemplary damages and costs in its November 18, 2005 decision.
Supreme Court review by petitioner (accused‑appellant) raising errors of credence of victim’s testimony, failure of prosecution to prove guilt beyond reasonable doubt, and failure to appreciate alibi corroborated by defense witnesses.
Disposition by the Supreme Court: CA decision reversed and set aside; appellant Larry Erguiza acquitted and ordered immediately released unless held for another lawful cause; costs de oficio; directives to Director of Bureau of Corrections to report release date.

Charged Offense and Allegations (Information)

Offense charged: Rape.
Date/time/alleged place of commission: on or about 5:00 p.m., January 5, 2000, at the back of Bical Norte Elementary School, Bayambang, Pangasinan.
Alleged means: accused purportedly armed with a kitchen knife; used force and intimidation to have sexual intercourse with AAA, a 13‑year‑old minor, against her will and consent, to her damage and prejudice.
Appellant’s plea at arraignment: “not guilty.”

Prosecution’s Version — Factual Narrative (as summarized by CA and trial testimony)

On January 5, 2000, at around 4:00 p.m., AAA, a 13‑year‑old first year high‑school student, went to a mango orchard behind ZZZ Elementary School to gather fallen mangoes with friends/siblings Joy and Ricky Agbuya.
When they were about to go home at around 5:00 p.m., AAA’s short pants got hooked on the fence; Joy and Ricky allegedly ran away and left her.
While AAA tried to unhook her short pants, Larry (appellant) suddenly grabbed and pulled her; he allegedly poked a knife at her neck and threatened to hurt her if she made noise.
Accused allegedly dragged AAA to a spot near a tamarind tree and thorny plants; removed his maong pants and forced AAA to lie on the ground; removed her short pants and panty; mounted her; inserted his penis and made push and pull movements; lifted her sando and fondled her breast.
AAA reported feeling pain on penetration and noticed something sticky in her private part after the sexual act; accused threatened her not to tell anyone or he would kill her and her family, then fled.
After some time AAA wore her clothing, went to her aunt’s adjacent store (Aunt Beth) where the aunt was asleep; later went home and directly to bed; out of fear AAA initially kept silent about the incident.
On April 7, 2000, BBB (mother) brought AAA to her grandmother (a hilot in XXX, Tarlac) due to unusual palpitation in mid‑portion of throat and absence of monthly period; the grandmother told BBB that AAA was pregnant.
After prodding and in presence of uncle Rudy Domingo, AAA revealed she was raped by appellant; on April 8, 2000, AAA and mother and uncle reported the incident at the police headquarters in YYY, Pangasinan.
AAA was taken to YYY District Hospital where Dr. James Sison examined her and found “no extragenital injuries noted. Complete healed hymenal laceration 11:00 o’clock,” and described the finding as suggestive (not conclusive) of rape; Dr. Sison testified that a single sexual intercourse could make a woman pregnant and suggested DNA match to determine paternity.
BBB testified AAA stopped going to school after the incident and that lost reputation could not be bought with money; CCC testified that the family of appellant visited on May 2, 2000 and offered money (initially P50,000 and later P150,000 per his testimony) and that on Jan. 5, while they were repairing his house for a wedding reception Larry left at around 4:00 p.m.

Defense’s Version — Factual Narrative and Alibi

Appellant’s defense: alibi corroborated by defense witnesses that on January 5, 2000 Larry helped repair CCC’s house from about 8:00 a.m. to 5:00 p.m.; after reaching home around 5:00 p.m., appellant’s mother Albina instructed him to fetch a hilot because his wife Josie was experiencing labor pains.
Appellant allegedly fetched hilot Juanita Angeles at about 5:10 p.m., returned home and the hilot stayed until appellant’s wife delivered a baby at around 3:00 a.m. on January 6, 2000; appellant did not leave his wife’s side.
Juanita Angeles corroborated that appellant fetched her around 5:10 p.m., they arrived at appellant’s house at 5:30 p.m., and appellant remained at home until the birth about 3:00 a.m.
Albina Erguiza (appellant’s mother) testified that she and appellant left CCC/BBB’s residence at about 5:00 p.m., appellant arrived home about 5:02–5:03 p.m., sent appellant to fetch a hilot, the hilot and appellant arrived by 5:30 p.m., and appellant never left the house thereafter.
Defense witness Joy Agbuya testified that she did not leave AAA at the orchard when AAA’s shorts got hooked and that she and AAA left together and parted at Aunt Beth’s store; Joy denied bringing her brother Ricky with them on that occasion.
Juanito Macaraeg, caretaker of the mango orchard, testified he did not see appellant in the orchard on January 5, 2000, but acknowledged appellant’s house was a short walk away (three minutes, or about one minute if walking fast).

Witnesses Presented and Key Testimony

Prosecution witnesses (four): AAA (private complainant), BBB (mother), CCC (father), Dr. James Sison (medical officer).
- AAA: narrated the alleged rape, time approximations (around 5:00 p.m.), details of assault, threats, aftermath and eventual report; stated she checked Joy’s wristwatch and it was 5:00 p.m.
- Dr. James Sison: medical exam found a complete healed hymenal lacer
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