Case Summary (G.R. No. 188108)
Factual Background
On March 3, 2004, at approximately 7:00 AM, AAA was alone in her house after washing dishes when Milagrosa forcibly carried her to a nearby grassy area. Despite her struggles and fear upon seeing a balisong (a type of folding knife) at his waist, AAA was overpowered. Milagrosa then committed sexual intercourse with her and left with a warning not to disclose the incident to anyone.
Charges and Defense
Milagrosa was charged with rape. In his defense, he claimed that it was impossible for him to carry AAA to the grassy area without drawing attention, given the early morning hour. He argued that AAA could have easily used the balisong against him and raised an alibi stating he was in Camp Crame at the time of the alleged incident.
Testimony and Credibility
AAA was the primary witness for the prosecution. She testified that she had known Milagrosa for a long time through her father and asserted the isolation of their home, making it plausible that her screams would not be heard by neighbors. The Regional Trial Court (RTC) found her testimony credible, leading to Milagrosa’s conviction for rape. He was sentenced to reclusion perpetua and required to pay P50,000.00 in civil indemnity and P50,000.00 in moral damages.
Court of Appeals Decision
On appeal, the Court of Appeals affirmed the RTC's ruling, underscoring that AAA’s positive testimony sufficed to establish Milagrosa's guilt beyond a reasonable doubt. The Court dismissed Milagrosa's argument that his age and employment as a carpenter detracted from his ability to overpower a 16-year-old girl. The remote setting of the crime was also discussed, noting that screams would unlikely be heard.
Conclusion and Final Review
This Court upheld the findings of the RTC, emphasizing that the conviction of rape can stand based solely on the credible testimony of the victim. The Court recognized the challenges in producing corroborating evidence in such cases, given their private nature. The defense of alibi was deemed weak a
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Case Information
- Court: Supreme Court of the Philippines
- Division: Third Division
- G.R. No.: 188108
- Date of Resolution: February 21, 2011
- Appellee: People of the Philippines
- Appellant: Evilio Milagrosa
Background of the Case
- The case revolves around the appeal filed by Evilio Milagrosa against the November 27, 2008 decision of the Court of Appeals (CA) in CA-G.R. CR-H.C. No. 02777.
- The incident occurred on March 3, 2004, at approximately 7:00 AM in Quezon Province.
- The victim, referred to as AAA, was a 16-year-old girl alone at her house after washing the dishes when Evilio Milagrosa forcibly entered her premises.
Incident Description
- Evilio Milagrosa approached AAA, forcibly carried her to a grassy area outside the house despite her struggles.
- AAA was intimidated by the sight of a balisong (a type of knife) tucked in Evilio's waist.
- He proceeded to remove her clothing and sexually assaulted her by inserting his penis into her vagina.
- After the assault, Evilio warned AAA against disclosing the incident to anyone.
Legal Proceedings
- Evilio was charged with the crime of rape.
- In his defense, he claimed:
- It was impossible for him to carry AAA given the time of day and proximity to neighbors who would hear her cries.
- AAA could have defended herself using the balisong.
- He presented an alibi, asserting he was at Camp Crame at the time of the incident.
- The prosecut