In People of the Philippines vs. John Glen Wile, et al., the Supreme Court affirmed the conviction of multiple accused for the crime of rape, emphasizing that a minor’s act of discernment overrides the privilege of mitigating circumstances typically afforded to youthful offenders. The Court underscored that even though some of the accused were minors at the time of the commission of the crime, their clear understanding and appreciation of the consequences of their actions nullified the possibility of reduced penalties. This decision highlights the principle that minors who demonstrate full awareness of their criminal acts can be held fully accountable under the law. The ruling serves as a stern warning, reinforcing the judiciary’s stance against sexual violence, regardless of the offender’s age.

Justice Undeterred: Fraternity Hazing Rituals Unmask Group Rape of Minors

This case involves a disturbing incident where members of the “Sana Wala Akong Kaaway” (SWAK) fraternity were accused of the gang rape of two minors, AAA and BBB, on July 26, 2005, in Silay City. The victims, invited to join the fraternity, were subjected to a brutal initiation rite involving sexual assault by multiple fraternity members. Further incidents occurred on September 12, 2005, when AAA was again victimized by two of the accused. The accused-appellants, John Glen Wile, Efren Buenafe, Jr., Mark Robert Lariosa, and Jaypee Pineda, were subsequently charged with multiple counts of rape under Article 266-A of the Revised Penal Code, as amended by Republic Act No. 8353, also known as the Anti-Rape Law of 1997. The legal question centered on the extent of criminal liability, especially considering that some of the accused were minors at the time of the offense.

During the trial, the prosecution presented compelling testimonies from the victims, medical evidence confirming hymenal lacerations, and corroborating accounts from relatives who noted the victims’ changed behavior post-assault. AAA and BBB recounted in vivid detail how they were blindfolded, led to a canefield, and subjected to repeated acts of rape while other members of the fraternity facilitated or participated in the crimes. Their detailed accounts underscored the element of force and intimidation, key components for proving rape under Philippine law. The medical examinations further corroborated their testimonies, providing physical evidence that supported their claims of sexual assault. The consistent and straightforward nature of their testimonies played a crucial role in establishing the guilt of the accused beyond a reasonable doubt.

The defense attempted to discredit the prosecution’s case by presenting an alternative narrative. Accused-appellants claimed that the incidents were part of a consensual fraternity initiation process and that the victims were willing participants. They also questioned the possibility of the rapes occurring in the alleged location due to its visibility and proximity to other houses. However, the court dismissed these arguments, emphasizing the credibility of the victims’ testimonies and the established facts of the case. The defenses of alibi and denial were deemed insufficient to overcome the weight of the evidence presented by the prosecution, particularly the positive identification of the accused by the victims.

Both the Regional Trial Court (RTC) and the Court of Appeals (CA) found the accused guilty beyond reasonable doubt. The RTC, in its original decision, considered the privileged mitigating circumstance of minority for John Glen Wile, Mark Robert Lariosa, and Jaypee Pineda, sentencing them to imprisonment terms of ten to fourteen years. Efren Buenafe, Jr., being an adult, received a sentence of Reclusion Perpetua. The CA affirmed the conviction but modified the penalties, adjusting the minimum and maximum terms of imprisonment for the minors, while maintaining the Reclusion Perpetua for Efren Buenafe, Jr. The CA also ordered the accused to pay civil indemnity and moral damages to the victims. However, it is important to note that the case record made no mention of any force or intimidation upon the victims during the commission of the crime.

The Supreme Court, in its analysis, addressed the core legal issues, particularly focusing on the application of Republic Act No. 9344, also known as the Juvenile Justice and Welfare Act of 2006, to the minor accused. The Court emphasized Section 6 of R.A. 9344, which stipulates that a child above fifteen but below eighteen years of age is not exempt from criminal liability if they acted with discernment. In this case, both the RTC and CA had determined that the minor accused had acted with discernment, effectively negating the mitigating effect of their age. Discernment, according to the Supreme Court, refers to the mental capacity of a minor to fully appreciate the consequences of their unlawful act.

Discernment is that mental capacity of a minor to fully appreciate the consequences of his unlawful act. Such capacity may be known and should be determined by taking into consideration all the facts and circumstances afforded by the records in each case.

The determination of discernment involves considering all the facts and circumstances of the case, including the nature of the crime and the minor’s cunning and shrewdness. In this case, the actions of the minor accused, such as willingly participating in the gang rape and helping each other to consummate the crimes, demonstrated a clear understanding of the consequences of their actions. Moreover, the Supreme Court affirmed the finding of conspiracy among the accused. This legal principle holds that when two or more persons agree to commit a crime and decide to pursue it, the act of one is the act of all. Given the coordinated actions of the accused in facilitating and participating in the rapes, the Court found sufficient evidence to establish a conspiracy.

Building on this principle, the Supreme Court referenced Article 266-B of the Revised Penal Code, which mandates that whenever rape is committed by two or more persons, the penalty shall be reclusion perpetua to death. Due to the absence of any mitigating or aggravating circumstances, the Court imposed the lesser penalty of reclusion perpetua on Efren Buenafe, Jr. Article 68(2) of the Revised Penal Code stipulates the penalty for offenders under eighteen years of age shall be the penalty next lower than that prescribed by law. In this case, the penalty was reduced by one degree from reclusion perpetua to reclusion temporal. The Court of Appeals did not err in imposing the indeterminate sentence with a minimum of six years and one day of prision mayor to a maximum of fourteen years, eight months, and one day of reclusion temporal for the minor accused.

The Supreme Court also addressed the issue of suspended sentences under Section 40 of Republic Act No. 9344. While suspension of sentence applies even if the child in conflict with the law is over eighteen years of age at the time of judgment, such suspension is only until the minor reaches the maximum age of twenty-one. Given that all the minor accused were already over twenty-one years old at the time of the Supreme Court’s decision, they were no longer eligible for a suspended sentence. Nevertheless, the Court acknowledged their entitlement to the benefits of Section 51 of Republic Act No. 9344, which allows convicted minors to serve their sentences in agricultural camps or training facilities rather than regular penal institutions. The civil liabilities were also addressed, with the Supreme Court affirming the CA’s award of P75,000.00 each for civil indemnity and moral damages to AAA and BBB, and adding an award of P75,000.00 each for exemplary damages.

FAQs

What was the key issue in this case?	The key issue was determining the criminal liability of the accused, particularly considering that some of them were minors at the time of the crime, and assessing whether their actions demonstrated sufficient discernment to negate the mitigating effects of their age.
What were the charges against the accused?	The accused were charged with multiple counts of rape under Article 266-A of the Revised Penal Code, as amended by Republic Act No. 8353, also known as the Anti-Rape Law of 1997.
What is the significance of “discernment” in this case?	Discernment refers to a minor’s mental capacity to fully understand the consequences of their actions. If a minor acted with discernment, they can be held criminally liable despite their age.
What was the Supreme Court’s ruling regarding the accused who were minors?	The Supreme Court upheld the lower courts’ findings that the minor accused acted with discernment, thus negating the mitigating effects of their age and affirming their conviction.
What penalties were imposed on the accused?	Efren Buenafe, Jr., the adult accused, was sentenced to reclusion perpetua for each count of rape. The minor accused, John Glen Wile, Mark Robert Lariosa, and Jaypee Pineda, were sentenced to imprisonment terms ranging from six years to fourteen years for each count, with the possibility of serving their sentences in agricultural camps or training facilities.
What is the Indeterminate Sentence Law, and how did it apply here?	The Indeterminate Sentence Law allows a court to impose a sentence with a minimum and maximum term, rather than a fixed term. In this case, it applied to the minor accused because their penalties were reduced due to their age.
Were the victims awarded damages?	Yes, the Supreme Court ordered the accused to jointly and severally pay each victim P75,000.00 as civil indemnity, P75,000.00 as moral damages, and P75,000.00 as exemplary damages for each count of rape.
What is the relevance of Republic Act No. 9344 in this case?	Republic Act No. 9344, the Juvenile Justice and Welfare Act of 2006, was relevant because it provides for the treatment of children in conflict with the law, including the possibility of suspended sentences and confinement in agricultural camps. However, its provisions were limited due to the finding of discernment and the accused’s age exceeding the eligibility for suspension of sentence.

In conclusion, People v. Wile reinforces the importance of holding individuals accountable for their actions, regardless of age, when they demonstrate a clear understanding of the consequences of their crimes. The ruling underscores the critical need to protect vulnerable members of society from sexual violence and to ensure that perpetrators face appropriate legal consequences. The Supreme Court’s decision serves as a deterrent and a reminder that justice will be served, even when the accused are minors, if they act with discernment.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. JOHN GLEN WILE, ET AL, G.R. No. 208066, April 12, 2016