G.R. No. 77912 March 6, 1990
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ERNESTO SANTOS, @ “KARIBA”, accused-appellant.

FACTS

The accused-appellant, Ernesto Santos, was convicted of statutory rape by the Regional Trial Court of Bulacan and sentenced to reclusion perpetua. The amended information alleged that on November 26, 1984, in Obando, Bulacan, he had carnal knowledge of nine-year-old Priscilla Marcos through force and intimidation. The prosecution’s evidence established that the victim’s mother, Pilar, had left the house that day. The victim was left with her aunt, Asuncion Marcos. When Asuncion went to a nearby store, the appellant entered the house. Finding Priscilla alone with her young brothers, he undressed her, laid on top of her, and inserted his penis into her vagina, causing her pain. Asuncion returned and saw the appellant on top of her naked niece. The appellant immediately dressed, warned them not to report the incident, and left. The matter was reported to the police that same evening. A medical examination revealed erythema of the labia minora and a superficial hymenal laceration.

ISSUE

The primary issue is whether the trial court erred in convicting the accused-appellant of rape beyond reasonable doubt, specifically concerning the admissibility and credibility of the child victim’s testimony and the sufficiency of the corroborative evidence.

RULING

The Supreme Court affirmed the conviction. The Court rejected the appellant’s contention that the ten-year-old victim was incompetent to testify under Rule 130, Section 19(b) of the Rules of Court. The law disqualifies only children of such tender age and inferior capacity as to be incapable of receiving correct impressions or relating them truly. The trial court found, and the Supreme Court agreed, that Priscilla’s clear, convincing, and naive narration of the event demonstrated her competence and the truthfulness of her account. Her testimony was sufficiently corroborated by the eyewitness account of her aunt, Asuncion, who saw the appellant on top of the naked victim, and by the medical findings consistent with sexual abuse. The Court noted that the relationship of the corroborating witnesses does not, by itself, impair their credibility, and it is inconceivable that a family would fabricate such a charge and subject a child to the ordeal of a trial. The defense of alibi also failed, as the appellant admitted his residence was merely about 20 meters from the victim’s house, making it not physically impossible for him to have been at the crime scene. The Court modified the civil aspect by increasing the award of moral damages from P10,000.00 to P50,000.00, recognizing the profound and lasting trauma inflicted upon the child victim.