G.R. No. 183652 February 25, 2015
PEOPLE OF THE PHILIPPINES and AAA, Petitioner, vs. COURT OF APPEALS, 21st DIVISION, MINDANAO STATION, RAYMUND CARAMPATANA, JOEFHEL OPORTO, and MOISES ALQUIZOLA, Respondents.

FACTS

Private respondents Raymund Carampatana, Joefhel Oporto, and Moises Alquizola, along with others, were charged with rape in a Second Amended Information. The prosecution alleged that on the evening of March 25, 2004, the accused conspired to force the 16-year-old minor AAA to drink intoxicating liquor at Alson’s Palace. Once intoxicated, she was brought to Alquizola Lodging House at dawn on March 26, 2004, where Carampatana and Oporto took turns having carnal knowledge against her will, while Alquizola kissed her against her will. AAA testified that she was forced to drink, fell in and out of consciousness, and was sexually assaulted. Medical examination confirmed the presence of sperm and hymenal laceration. The defense presented a different version, claiming AAA voluntarily drank, kissed the accused, and consented to sexual acts. The Regional Trial Court (RTC) found Carampatana, Oporto, and Alquizola guilty beyond reasonable doubt. The Court of Appeals (CA) reversed the RTC decision and acquitted them, prompting the People to file a Petition for Certiorari before the Supreme Court.

ISSUE

Whether the Court of Appeals committed grave abuse of discretion in acquitting private respondents of the crime of rape.

RULING

The Supreme Court dismissed the petition and affirmed the acquittal. The Court held that a petition for certiorari under Rule 65 is not the proper remedy to assail a judgment of acquittal. An acquittal is immediately final and cannot be appealed without placing the accused in double jeopardy. The extraordinary writ of certiorari may only be granted if the prosecution can clearly demonstrate that the trial court committed grave abuse of discretion amounting to lack or excess of jurisdiction, such as where the prosecution was denied due process or where the acquittal was based on a demurrer to evidence that the court granted with grave abuse of discretion. In this case, the prosecution failed to prove such grave abuse. The CA’s decision was based on its evaluation of the evidence, finding the testimony of AAA inconsistent and incredible, while the defense’s version was coherent and supported by other witnesses. The CA concluded that the prosecution failed to prove guilt beyond reasonable doubt. The Supreme Court found no capricious, whimsical, or arbitrary exercise of judgment by the CA that would constitute grave abuse of discretion. Therefore, the acquittal stands.