GR 128789; (May, 1999) (Digest)
G.R. No. 128789 May 24, 1999
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RENATO CAPARANGA JOSE, accused-appellant.
FACTS
Accused-appellant Renato Caparanga Jose was convicted of statutory rape and sentenced to death by the RTC of Parañaque. The victim, Aimzyl Tria, was a five-year-old child. The prosecution established that on February 6, 1995, the accused, who was known to the victim, found her alone at home. He brought her to a bedroom, undressed her, and sexually assaulted her by licking her private part and inserting his fingers and penis into her vagina. He threatened her to keep quiet. The victim experienced extreme pain. A subsequent medical examination revealed the presence of sperm cells and gram-negative diplococci in her vaginal smear, confirming sexual abuse and infection with gonorrhea. The victim’s mother discovered the assault after noticing mucus on her daughter’s underwear and, upon persistent questioning, the child identified her assailant as “Kuya Nat.”
ISSUE
The primary issue for the Supreme Court’s review was the correctness of the conviction and the imposition of the death penalty. A subsidiary issue concerned the proper award of civil liabilities.
RULING
The Supreme Court affirmed the conviction and the imposition of the death penalty. The Court found the victim’s testimony, given in a straightforward and candid manner consistent with her tender age, to be credible and sufficient to establish the crime. Her young age rendered her incapable of fabricating a tale of sexual abuse. The medical findings corroborated her account, proving penile penetration and the resulting sexually transmitted disease. The crime qualified for the death penalty under Article 335 of the Revised Penal Code, as amended by R.A. No. 7659, because the victim was under seven years old. Regarding civil liability, the Court modified the trial court’s award. It held that in rape cases, civil indemnity in the amount of P75,000.00 is automatically granted without need of proof. Furthermore, moral damages in the amount of P50,000.00 are also automatically awarded, as the trauma and psychological suffering of a rape victim are inherent and presumed from the commission of the crime itself, dispensing with the need for specific pleading or proof.