Case Summary (G.R. No. 183709)
Factual Antecedents
On March 16, 2004, an information was filed against Pojo, charging him with statutory rape against "AAA," occurring on October 20, 2003. The charge stated that Pojo unlawfully engaged in sexual intercourse with "AAA," utilizing force or intimidation. During the trial, "AAA" testified regarding the incident, asserting that Pojo forced her to remove her clothing and attempted to penetrate her. After the abuse, she reported the incident to her family, who subsequently notified the police.
Prosecution's Version
According to "AAA," Pojo was working at a plantation and her mother sent her to deliver food to him. Once there, he coerced her into a vulnerable position, resulting in attempted carnal knowledge. Although penetration was incomplete, "AAA" stated that she felt pain during the encounter. The victim recounted the incident to her sibling and mother immediately upon returning home, leading to a medical examination and police report.
Defense's Version
Pojo admitted his relationship with "AAA’s" mother but denied the charges, claiming he was in Batangas on the date the crime was said to have occurred. He alleged that "AAA" had an ulterior motive for accusing him, which was to pressure him into marrying her mother.
Ruling of the Regional Trial Court
The Regional Trial Court gave credence to "AAA's" testimony, asserting that rape was still deemed to have occurred despite the lack of full penetration. The court reasoned that due to her young age, "AAA" could not have fabricated the claim. Pojo's alibi was dismissed as self-serving and unsupported, leading to his conviction for statutory rape, with a sentence of reclusion perpetua and damages awarded to "AAA."
Ruling of the Court of Appeals
The Court of Appeals upheld the Regional Trial Court's decision in full, agreeing with the trial court's evaluation of evidence and findings. It deemed Pojo's denials and alibi unconvincing due to the absence of corroborative evidence and dismissed his claims about "AAA's" motives as improbable given her age.
Court's Ruling
The Supreme Court found no merit in Pojo's appeal. It refuted the defense's suggestion that "AAA" harbored ill motives against Pojo, pointing out inconsistencies in the defense’s arguments. The Court also deemed the timing of "AAA's" report reasonable and credible, noting that a 27-day delay in signing her affidavit did not undermine her credibility.
Legal Basis for Guilt
The Court confirmed that the prosecution met its burden of proof as defined under Article 266-A(1)(d) of the Revised Penal Code, establishing that Pojo had sexual contact with a victim below the age of twelve, thus affirming the statutory ra
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Case Information
- Case Citation: 651 Phil. 262
- Division: First Division
- G.R. No.: 183709
- Date of Decision: December 06, 2010
- Parties: People of the Philippines (Appellee) vs. Manuel "Awil" Pojo (Appellant)
Background of the Case
- The case revolves around the appeal of Manuel "Awil" Pojo regarding his conviction for statutory rape.
- The Court of Appeals (CA) Decision dated January 28, 2008, affirmed the Regional Trial Court (RTC) Decision dated September 4, 2006, which found Pojo guilty beyond reasonable doubt.
Factual Antecedents
- Incident Date: October 20, 2003
- Victim: "AAA," a ten-year-old girl, daughter of Pojo's common-law spouse.
- Incident Description:
- On the day of the incident, "AAA" was sent by her mother to bring food to Pojo at a camote plantation.
- Pojo allegedly made "AAA" lie down on the ground covered with banana leaves, ordered her to remove her shorts and panty, and attempted to have carnal knowledge of her.
- Although complete penetration did not occur, "AAA" reported feeling pain and observed a whitish substance from Pojo's private part.
- Upon returning home, "AAA" disclosed the incident to her mother and sibling, leading to a police report and medical examination.
Version of the Prosecution
- "AAA" testified against Pojo, detailing the assault and her immediate actions post-incident.
- The prosecution established that Pojo had carnal knowledge of "AAA" through force and intimidation without her consent.
Version of the Defense
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