G.R. No. 252865 - People vs. YYY

Case Summary (G.R. No. 252865)

Petitioner and Respondent

Petitioner in the appeal: YYY (accused‑appellant). Respondent: People of the Philippines (plaintiff‑appellee). Lower court decisions under review: RTC Branch 63 decision (February 13, 2018) convicting YYY of four counts of statutory rape and acquitting him in one count (Criminal Case No. 09‑1413); Court of Appeals decision (October 1, 2019) affirming the RTC with modification to the damages awarded.

Charges and Informations

YYY was charged in five separate Informations (Criminal Case Nos. 09‑1411 to 09‑1415) with five counts of statutory rape under Article 266‑A(1)(d) as amended by RA 8353. The accusatory allegations describe repeated acts of sexual intercourse (penetration or attempted penetration) against two minors: AAA (age two at the time) and BBB (age eight at the time), committed on or about January 24–26, 2007.

Arraignment and Plea

When arraigned on August 25, 2009, the accused pleaded not guilty to all charges. Trial followed with the prosecution and the defense presenting testimony and evidence.

Prosecution’s Version and Evidence at Trial

The prosecution presented testimony of AAA and BBB describing that YYY undressed them and sexually assaulted them on multiple dates in January 2007; BBB consistently testified to being raped three times with penile insertion into her vagina, and AAA testified to at least one instance of penile insertion causing pain. The victims positively identified YYY as the perpetrator. The prosecution also relied on the victims’ mother’s testimony regarding disclosure by AAA and on medico‑legal reports (BRO‑MG‑08‑111 and BRO‑MG‑08‑110) prepared by Dr. Raoul V. Alcantara noting no recent extragenital physical injury and no sign of recent or previous injury to the hymen for either child.

Defense Version

YYY denied the allegations and asserted an alibi that he was working elsewhere as a store helper on the dates in question. He also claimed he was 17 years old at the time of the incidents (a claim of minority). Defense witnesses included YYY’s mother (ZZZ) and a neighbor, but no documentary proof of YYY’s date of birth was produced to corroborate the minority claim.

Medico‑Legal Findings

The medico‑legal reports showed absence of recent extragenital injuries and no signs of hymenal laceration or rupture. The courts below, and ultimately the Supreme Court, treated these findings as corroborative but not essential, emphasizing that medical findings are not indispensable where credible, consistent victim testimony establishes the fact of sexual intercourse and the identity of the perpetrator.

RTC Ruling

The RTC (Branch 63) found YYY guilty beyond reasonable doubt of four counts of statutory rape (Criminal Case Nos. 09‑1411, 09‑1412, 09‑1414, 09‑1415) and acquitted him in Criminal Case No. 09‑1413. The RTC credited the victims’ testimonies as clear, simple, spontaneous and straightforward, invoking the principle that youth and immaturity are generally badges of truth. The RTC sentenced YYY to reclusion perpetua without eligibility for parole and awarded civil indemnity, moral damages, exemplary damages, and costs of suit in varying amounts to the victims.

Court of Appeals Ruling

The Court of Appeals denied YYY’s appeal, affirming the RTC’s conviction but modifying the quantum of damages. The CA concluded that because AAA was below seven years of age when the sexual act occurred, the proper designation was Qualified Statutory Rape and AAA was entitled to higher damages (P100,000 each for civil indemnity, moral and exemplary damages) while BBB’s awards were set at P75,000 each.

Issue on Appeal to the Supreme Court

The principal issue presented to the Supreme Court was whether the CA erred in affirming YYY’s conviction. YYY reiterated his claims that (1) he acted without discernment because he was a minor (allegedly 17) at the time of the offenses; (2) the prosecution’s evidence was insufficient; and (3) his denial and alibi were credible defenses.

Supreme Court Ruling — Minority Claim and Evidentiary Burden

The Supreme Court rejected the accused’s claim of minority as self‑serving and unsupported. Citing Section 7 of RA 9344 and Rule 35.b of its IRR, the Court observed that age should be determined from birth certificates or other pertinent documents, and testimonial evidence of age may be given weight only in the absence of such documents. Here, YYY failed to produce any documentary proof of his date of birth, and the testimonies that could have corroborated his minority did not emphasize or establish his age. The Court noted that the accused did not explain his failure to obtain a document proving his date of birth and concluded that he did not meet the evidentiary threshold to invoke minority.

Supreme Court Ruling — Sufficiency of Evidence and Credibility

On the merits, the Supreme Court found the prosecution proved guilt beyond reasonable doubt. The Court emphasized: (a) the uncontested documentary proof of the victims’ ages (birth certificates); (b) the victims’ consistent, categorical and positive identifications of YYY; (c) that for statutory rape under Article 266‑A the crucial elements are proof of the victim’s age (under 12) and proof of carnal knowledge, with absence of consent conclusively presumed; (d) that slight penetration suffices to consummate rape; and (e) that the victims’ youth and immaturity, the nature of their testimony, and the attendant trauma make their testimony reliable and persuasive. The Court treated the medico‑legal reports as corroborative only and declined to allow them to override the victims’ credible accounts.

Supreme Court Ruling — Alibi and Other Defenses

The Court found the asserted alibi unpersuasive. To succeed, an alibi must not only show the accused’s presence elsewhere but must show it was impossible for him to be at the scene; here the place relied upon by YYY as an alibi was only six to seven kilometers from the crime scene and easily accessible, so the alibi did not preclude the accused’s presence. The Court also reiterated jurisprudential guidance that alibi is generally a weak and easily fabricated defense and cannot prevail over credible positive identification.

Designation of Offenses, Penalties, and Damages

The Supreme Court concluded YYY was guilty of one count of Qualified Stat

Case Syllabus (G.R. No. 252865)

Procedural Posture

Petition for review involves an appeal to the Supreme Court from the Court of Appeals (CA) Decision dated October 1, 2019 in CA-G.R. CR-HC No. 11075.
The CA had affirmed the Regional Trial Court (RTC), Branch 63, decision dated February 13, 2018 which found accused-appellant YYY guilty beyond reasonable doubt of four counts of Statutory Rape, and had modified the damages awarded.
Accused-appellant filed a Notice of Appeal from the CA decision; the Supreme Court considered whether the CA erred in affirming the conviction.
The case bears G.R. No. 252865 and the Supreme Court promulgated its decision on August 4, 2021, penned by Justice Inting with Justices Perlas-Bernabe (Chairperson), Hernando, Carandang, and Gaerlan concurring.

Antecedents and Informations Filed

The prosecution filed five separate Informations before the RTC, docketed as Criminal Case Nos. 09-1411, 09-1412, 09-1413, 09-1414, and 09-1415.
The accused-appellant YYY was charged with five counts of Statutory Rape under Article 266-A paragraph (1)(d) of the Revised Penal Code, as amended by Republic Act No. 8353 (the Anti-Rape Law of 1997).
The alleged victims were two siblings identified in the record as AAA and BBB, whose identities and identifying information were withheld pursuant to RA 7610, RA 9262, Section 40 of Administrative Matter No. 04-10-11-SC, and related protocols.

Accusatory Portions of Each Information (as alleged)

Criminal Case No. 09-1411 (alleged date on or about January 24, 2007): Accused-appellant, moved by sexual lust and with lewd design, allegedly, by force and intimidation, had carnal knowledge of AAA, then two years old (born March 8, 2004), minor, against her will and consent.
Criminal Case No. 09-1412 (alleged date on or about January 24, 2007): Accused-appellant, moved by sexual lust and with lewd design, allegedly, by force and intimidation, had carnal knowledge of BBB, then eight years old (born October 7, 1998), minor, against her will and consent.
Criminal Case No. 09-1413 (alleged date on or about January 25, 2007): Accused-appellant, moved by sexual lust and with lewd design, allegedly, by force and intimidation, had carnal knowledge of AAA, then two years old, minor, against her will and consent.
Criminal Case No. 09-1414 (alleged date on or about January 25, 2007): Accused-appellant, moved by sexual lust and with lewd design, allegedly, by force and intimidation, had carnal knowledge of BBB, then eight years old, minor, against her will and consent.
Criminal Case No. 09-1415 (alleged date on or about January 26, 2007): Accused-appellant, moved by sexual lust and with lewd design, allegedly, by force and intimidation, had carnal knowledge of BBB, then eight years old, minor, against her will and consent.

Arraignment and Plea

Accused-appellant was arraigned on August 25, 2009.
He pleaded not guilty to all charges.

Prosecution’s Version (chronology and core factual claims)

January 24, 2007: AAA (age two) and BBB (age eight) were at accused-appellant’s house; accused removed his clothes and BBB’s shorts and panty, placed himself on top of BBB, and inserted his penis into BBB’s vagina; BBB pushed him until he stopped; accused then undressed AAA, laid on top of her, and BBB tried to pull him away; accused left.
January 25, 2007: While the victims’ parents were away harvesting copra, accused entered the victims’ house, undressed BBB, spread her legs, and inserted his penis into her vagina; BBB felt pain and kicked accused; accused then undressed AAA and laid on top of her; BBB kicked when accused tried to insert his penis into AAA’s vagina; accused left.
January 26, 2007: BBB entered accused-appellant’s house searching for his mother; accused pushed BBB inside, placed her on a table, removed her shorts and panty, spread her legs, and inserted his penis into her vagina but was not able to fully penetrate because BBB kept pushing him until he left.
After several days, AAA informed her mother of what accused-appellant did to them.
Trial testimony: AAA testified accused inserted his penis into her vagina causing pain and that the incident happened once; BBB consistently stated she was raped three times and that penile insertion into her vagina caused pain.
Both victims positively identified accused-appellant as the perpetrator.

Defense’s Version

Accused-appellant denied the allegations.
He claimed that on January 24, 25, and 26, 2007, he was working as a stay-in store helper for a person identified in the records (name redacted).
Accused-appellant argued the criminal cases were motivated by a quarrel between his parents and the victims’ parents over a parcel of land.
The defense presented testimony from accused-appellant’s mother, ZZZ, and a neighbor, but did not produce documentary proof of accused-appellant’s date of birth to substantiate his claim of minority.

Medico-Legal Findings

Medico-Legal Report Nos. BRO-MG-08-111 and BRO-MG-08-110 by Dr. Raoul V. Alcantara noted no recent extragenital physical injury and no sign of either recent or previous injury to the hymen for both AAA and BBB.
The records reflect that the medico-legal report showed absence of hymenal laceration or rupture; however, the reports were treated as corroborative and not indispensable to proving rape.

RTC Decision (February 13, 2018) — Findings and Disposition

The RTC found accused-appellant guilty beyond reasonable doubt of four counts of Statutory Rape and acquitted him in Criminal Case No. 09-1413.
The RTC gave full weight and credit to the testimonies of AAA and BBB, finding their statements clear, simple, spontaneous, and straightforward; it co