GR 182191; (May, 2009) (Digest)
G.R. No. 182191 ; May 8, 2009
THE PEOPLE OF THE PHILIPPINES, Appellee, vs. LORENZO LAYCO, SR., Appellant.
FACTS
Appellant Lorenzo Layco, Sr. was convicted by the Regional Trial Court of nine counts of qualified rape against his two daughters, AAA and BBB. The charges stemmed from incidents in January 1993 against the 11-year-old AAA, and multiple incidents between 1993 and 1997 against the 7-year-old BBB. Both victims provided detailed testimonies describing the rapes, which were preceded by physical violence and occurred inside their family home. AAA escaped in 1993 and later, upon a visit home, witnessed appellant assaulting BBB. This prompted AAA to secure BBB’s custody, after which both sisters formally reported the crimes to the NBI. Medical examinations confirmed hymenal lacerations consistent with sexual abuse. The defense relied on denial and alibi, supported by testimonies from appellant’s wife and sons, claiming the daughters were not living with him during the alleged periods.
ISSUE
Whether the Court of Appeals erred in affirming appellant’s conviction for nine counts of statutory rape.
RULING
The Supreme Court affirmed the conviction. The legal logic centered on the elements of statutory rape and the credibility of the victims’ testimonies. For statutory rape under Article 335 of the Revised Penal Code, the prosecution must prove: (1) the complainant was below twelve years old, (2) the identity of the accused, and (3) sexual intercourse occurred. All elements were established. The victims’ birth certificates proved their ages at the time of the crimes. Their positive, clear, and categorical identification of their father as the perpetrator was deemed credible and was corroborated by medical findings of hymenal injuries. The Court emphasized that the trial court’s assessment of witness credibility is accorded great weight and respect on appeal, absent any showing of arbitrariness. Appellant’s defense of denial and alibi, inherently weak against positive identification, was rightly rejected. The alleged inconsistencies in the victims’ testimonies, such as BBB’s inability to recall exact dates, were deemed minor and inconsequential, as precise dates are not an essential element of the crime. The penalties were modified in line with Republic Act No. 9346 , commuting death sentences to reclusion perpetua, and damages were adjusted in accordance with prevailing jurisprudence.