G.R. No. 265302 – People of the Philippines v. CICL XXX265302
Promulgated: April 2, 2025
Ponente: Lopez, M., J.
(En Banc)
Core Holding (Ratio Decidendi)
The Supreme Court affirmed the conviction of the accused-appellant (a Child in Conflict with the Law – CICL) for statutory rape under Article 266-A(1)(d) of the Revised Penal Code, as amended, and upheld the penalty of reclusion perpetua imposed by the Court of Appeals, with modifications only on the amounts of damages.
Principal Doctrines Reaffirmed / Clarified
1. Effect of R.A. 9346 (2006) on the graduation of penalties (Article 71, RPC)
Since the enactment of Republic Act No. 9346 (Act Prohibiting the Imposition of Death Penalty), the penalty of death has been completely removed from the Philippine legal system. Consequently, “death” is no longer included as a reference point in the computation of penalty graduation under Article 71 of the Revised Penal Code.
→ This is a reiteration of the long-standing doctrine first clearly enunciated in People v. Bon (G.R. No. 166199, 2006).
2. **Elements of Statutory Rape under Art. 266-A(1)(d), RPC** (as it stood in 2014)
Only two elements need to be proven:
1. The offender had carnal knowledge of the victim (sexual intercourse);
2. The victim was under 12 years of age at the time of the incident.
All other circumstances (force, threat, intimidation, unconsciousness, fraud, abuse of authority) are immaterial.
The law conclusively presumes that a child below 12 years old cannot give valid consent to sexual intercourse due to lack of discernment and maturity.
3. Qualifying circumstance – victim below 7 years old
When the victim is below 7 years of age, the crime is qualified and carries the penalty of reclusion perpetua (Art. 266-B, as then worded).
4. Appreciation of child-victim testimony in statutory rape cases
The testimony of a child-victim of tender age is generally given great weight when it is clear, candid, straightforward, and consistent on material points, especially regarding the identity of the perpetrator and the basic fact of sexual abuse.
Minor inconsistencies, particularly those concerning peripheral matters or arising from the limited vocabulary and recollection ability of a very young child, do not destroy credibility.
5. **Discernment in CICL cases involving serious crimes (rape)**
The prosecution sufficiently established **discernment** through circumstantial evidence consisting of the accused’s:
- deliberate invitation of the victim,
- commission of the act in isolation (only girl among several children),
- removal of clothing of both parties,
- performance of the sexual act, and especially
- **subsequent threat** to the victim not to tell anyone (“or he would punch her”).
The Court considered these acts as clear indicia that the CICL **understood the wrongfulness** of the act and its moral and legal consequences.
Factual Summary (material points)
- Victim (AAA): 6 years old (born June 25, 2009)
- Accused (CICL XXX): 15 years old at the time of the incident (December 2014)
- Incident: penile-vaginal penetration inside the accused’s house
- Key evidence: testimony of the child-victim (very candid demonstration using fingers), corroborated by an eyewitness child (Ken)
- Medico-legal finding of intact hymen not considered decisive (penetration need not result in hymenal laceration in statutory rape)
- Defense: denial + alibi + attempt to shift blame to other children → rejected
Final Disposition
- Conviction for statutory rape (qualified – victim below 7 years old) AFFIRMED
- Penalty: reclusion perpetua (as modified by CA)
- Civil liability (increased by CA and upheld):
- Civil indemnity → ₱75,000
- Moral damages → ₱75,000
- Exemplary damages → ₱75,000
- Interest at 6% p.a. from finality until full payment
Summary of Most Important Legal Teaching
In statutory rape cases involving victims under 12 (especially under 7), the Supreme Court continues to apply an **extremely protective stance** toward the testimony of very young victims. At the same time, the Court maintains the strict requirement of **proof beyond reasonable doubt of carnal knowledge** and, in CICL cases, of **discernment** — which may be inferred from the deliberate, conscious, and surreptitious manner of commission and from post-act efforts to conceal the crime (such as threats to the victim).
The decision also serves as a firm reminder that R.A. 9346 has permanently removed death from the entire penalty structure of the RPC, including for purposes of penalty graduation.
Digest and Analysis of Supreme Court Decision
G.R. No. 265302 – People of the Philippines v. CICL XXX265302
Promulgated: April 2, 2025
Ponente: Lopez, M., J.
(En Banc)
Core Holding (Ratio Decidendi)
The Supreme Court affirmed the conviction of the accused-appellant, a Child in Conflict with the Law (CICL), for qualified statutory rape under Article 266-A(1)(d) in relation to Article 266-B of the Revised Penal Code, as amended. The Court imposed a penalty of imprisonment ranging from 12 years to 14 years, eight months, and one day, but ordered the suspension of the sentence pursuant to Republic Act No. 9344 (RA 9344), as amended, emphasizing the rehabilitative purpose of the juvenile justice system. The case was remanded to the Regional Trial Court for the implementation of appropriate disposition measures, including potential confinement in an agricultural camp or training facility under Section 51 of RA 9344.
Principal Doctrines Reaffirmed / Clarified
1. Effect of R.A. 9346 (2006) on the Graduation of Penalties (Article 71, RPC)
The enactment of Republic Act No. 9346 has permanently excised the death penalty from the Philippine penal framework. Consequently, "death" is excluded as a benchmark in the graduation of penalties under Article 71 of the Revised Penal Code. This principle, initially articulated in *People v. Bon* (G.R. No. 166199, 2006), ensures that penalty computations for crimes previously punishable by death are adjusted downward, with reclusion perpetua serving as the maximum reference point.
2. Elements of Qualified Statutory Rape under Art. 266-A(1)(d) and Art. 266-B, RPC
Statutory rape requires proof of: (1) carnal knowledge of the victim by the offender, and (2) the victim's age being under 12 years at the time of the offense (amended to under 16 years by Republic Act No. 11648 in 2022, but the pre-amendment threshold applies here as the incident occurred in 2014). Force, threat, intimidation, or abuse of authority are irrelevant, as the law presumes the absence of valid consent due to the child's immaturity. The offense is qualified, warranting a higher penalty, when the victim is below seven years old, as in this case where the victim was five years old.
3. Appreciation of Child-Victim Testimony in Rape Cases
The testimony of a young child-victim is accorded substantial credence if it is delivered in a clear, straightforward, and consistent manner, particularly on core elements such as the perpetrator's identity and the occurrence of sexual intercourse. Minor inconsistencies arising from the child's age, limited vocabulary, or traumatic recollection do not undermine credibility, especially when corroborated by eyewitness accounts or medical evidence.
4. Discernment in Cases Involving CICL
For a minor aged 15 to below 18, criminal liability attaches only upon proof of discernment—the capacity to understand the wrongfulness of the act and its consequences. Discernment is inferred from circumstantial evidence, including the deliberate planning of the offense (e.g., inviting the victim to an isolated location), the manner of execution (e.g., undressing and threatening the victim), and post-offense conduct (e.g., warnings to maintain silence). In this instance, the accused's actions demonstrated clear discernment.
Factual Summary (Material Points)
- Victim (AAA265302): Five years old (born June 25, 2009) at the time of the incident in December 2014.
- Accused (CICL XXX265302): Fifteen years old (born May 26, 1999) at the time of the offense, acting with discernment.
- Incident: The accused invited the victim and other children to his home, isolated her, removed her clothing, and engaged in penile-vaginal penetration, causing pain. He threatened her to remain silent. An eyewitness (another minor) corroborated the act.
- Key Evidence: The victim's candid testimony, including a finger demonstration of the act; eyewitness account; Certificate of Live Birth confirming age; medico-legal report (intact hymen not dispositive, as full penetration is not required).
- Defense: Denial, alibi (presence elsewhere), and attempt to implicate other children—rejected as inconsistent and uncorroborated.
- Lower Court Proceedings: The Regional Trial Court convicted the accused of statutory rape, imposed a reduced penalty (eight years and one day to 14 years, eight months, and one day) considering minority as a mitigating circumstance, and suspended the sentence under Section 38 of RA 9344. A warrant was issued upon the accused reaching majority. The Court of Appeals affirmed the conviction but modified the penalty to reclusion perpetua without suspension.
Final Disposition
- Conviction: Affirmed for qualified statutory rape.
- Penalty: Imprisonment from 12 years to 14 years, eight months, and one day (after applying the privileged mitigating circumstance of minority and excluding death as a penalty under RA 9346).
- Suspension of Sentence: Ordered, with remand to the trial court for implementation of rehabilitative measures.
- Civil Liability: Civil indemnity of ₱75,000; moral damages of ₱75,000; exemplary damages of ₱75,000; all with 6% interest per annum from finality until payment.
Thorough Discussion on the Application of Suspended Sentence Where the Accused is a Child
The Supreme Court's application of a suspended sentence in this case exemplifies the rehabilitative ethos of the Philippine juvenile justice system under RA 9344, titled the "Juvenile Justice and Welfare Act of 2006," as amended by Republic Act No. 10630 in 2013. This framework prioritizes the restoration, rehabilitation, and reintegration of Children in Conflict with the Law (CICL) over punitive measures, recognizing that children, due to their developmental stage, possess greater potential for reform. The discussion below elucidates the legal basis, procedural application, exceptions, and rationale as applied in this decision, drawing from the Court's reasoning and statutory provisions.
Legal Basis Under RA 9344
Section 38 of RA 9344 mandates the automatic suspension of sentence for any CICL found guilty who was under 18 years old at the time of the offense's commission. This provision states: "Once the child who is under eighteen (18) years of age at the time of the commission of the offense is found guilty of the offense charged, the court shall determine and ascertain any civil liability which may have resulted from the offense committed. However, instead of pronouncing the judgment of conviction, the court shall place the child in conflict with the law under suspended sentence, without need of application: Provided, however, That suspension of sentence shall still be applied even if the juvenile is already eighteen years (18) of age or more at the time of the pronouncement of his/her guilt."
Key features include:
- Automatic Application: No formal application is required; suspension is imposed ipso jure upon conviction if the age criterion is met.
- Focus on Age at Commission: The determinative factor is the accused's age when the crime occurred (here, 15 years), not at arraignment, trial, sentencing, or appeal. This aligns with the law's child-centric approach, presuming diminished moral culpability in minors.
- Civil Liability Unaffected: The Court must still assess and award damages, as done here with increased amounts to reflect the gravity of qualified rape.
Section 40 complements this by addressing post-18 scenarios: Upon reaching 18 while under suspension, the court may (1) discharge the CICL if rehabilitated, (2) execute the sentence if rehabilitation fails, or (3) extend the suspension until age 21. In this case, the Supreme Court extended the suspension further, citing its precedent in People v. Jacinto (G.R. No. 182239, March 16, 2011), which held that the CICL's age at judgment is irrelevant—what matters is minority at the time of the offense to afford opportunities for reform.
For offenses carrying penalties exceeding six years (such as reclusion perpetua for qualified rape), Section 51 authorizes commitment to an agricultural camp, training facility, or youth rehabilitation center managed by the Department of Social Welfare and Development (DSWD) or local government units. The Court remanded the case to the RTC for this purpose, ensuring oversight of the accused's progress toward reintegration.
Application in This Case
The accused, now approximately 26 years old (as of the 2025 promulgation), benefited from suspension despite the heinous nature of qualified rape. The trial court initially suspended the sentence in 2017, but the Court of Appeals erroneously imposed reclusion perpetua without suspension, overlooking RA 9344's mandates. The Supreme Court rectified this by:
- Recognizing the privileged mitigating circumstance of minority (Article 68, RPC), reducing the penalty from reclusion perpetua (after excluding death under RA 9346) to a determinate term of 12 to 14 years, eight months, and one day.
- Ordering suspension to prioritize rehabilitation, noting the accused's potential to "live a normal life and become a productive member of the community."
- Remanding for DSWD-supervised intervention, including counseling and therapy as recommended in the Social Case Study Report, which found discernment but emphasized the need for realizations through diversion programs.
This approach underscores that RA 9344 applies universally to CICL, irrespective of the crime's severity, unless explicitly exempted (e.g., under Section 6 for children below 15 without discernment, who are exempt from liability altogether). No such exemption exists for rape cases.
Exceptions and Limitations
While suspension is generally mandatory, it is not absolute:
- Failure to Reform: If the CICL commits another offense or fails intervention conditions, the court may lift the suspension and impose the original penalty (Section 40).
- Serious Offenses in Practice: For crimes like qualified rape, suspension does not equate to impunity; it shifts focus to restorative justice. Commitment under Section 51 ensures accountability through structured rehabilitation, potentially lasting until age 21 or beyond if extended.
- Age Thresholds: Suspension ceases automatically at age 21 unless extended, but the Court here invoked its equity jurisdiction to prolong it, prioritizing the child's best interests (Section 2, RA 9344).
Rationale and Broader Implications
The Court's decision reaffirms RA 9344's alignment with international standards, such as the United Nations Convention on the Rights of the Child, emphasizing that juvenile offenders should be treated with dignity and given opportunities for redemption. By suspending the sentence, the Supreme Court balances victim protection (through affirmed conviction and damages) with offender rehabilitation, avoiding the societal costs of lifelong incarceration for youthful errors. This ruling serves as precedent that suspension applies even in grave cases like qualified rape, provided the accused was a minor at commission, and reinforces the need for courts to integrate social welfare assessments (e.g., discernment tools and intervention programs) into proceedings.
Summary of Most Important Legal Teaching
This decision highlights the Supreme Court's commitment to a restorative juvenile justice system, where suspension of sentence for CICL in serious offenses like qualified rape promotes rehabilitation without diminishing accountability. It clarifies that statutory protections under RA 9344 prevail over punitive inclinations, ensuring that the child's age at the offense governs eligibility for leniency.
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Assisted by Grok, January 15 2026.
