GR 175876; (February, 2013) (Digest)
G.R. No. 175876 ; February 20, 2013
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. TOMAS TEODORO y ANGELES, Accused-Appellant.
FACTS
Accused-appellant Tomas Teodoro was charged with two counts of statutory rape against AAA, the eight-year-old daughter of his common-law wife, BBB. The first incident allegedly occurred on December 18, 1997, and the second on February 8, 1998, in Kitcharao, Agusan del Norte. During the initial trial, AAA and her mother BBB provided detailed testimonies for the prosecution, describing the rapes. The medical examination of AAA revealed findings consistent with sexual abuse.
However, two years later, both AAA and BBB recanted their testimonies, turning hostile to the prosecution. They claimed that Teodoro had only touched or caressed AAA and had not committed rape. Teodoro, for his defense, admitted to touching AAA on one occasion but claimed it was a mistake in the dark, thinking she was BBB. He denied the rape allegations.
ISSUE
Whether the recantation of testimonies by the victim and her mother should be given credence to exonerate the accused.
RULING
No. The Supreme Court affirmed the conviction, holding that the recantations were unreliable and should be disregarded. The Court emphasized that a recantation is exceedingly unreliable, especially when it comes long after the original testimony and would result in the acquittal of a guilty individual. It is viewed with suspicion and is considered inferior to the testimony given in open court under oath and subject to cross-examination.
The legal logic rests on the principle that a testimony solemnly given in court carries more weight than a subsequent retraction, which is often motivated by external pressures. The Court found that the original testimonies of AAA and BBB were clear, credible, and consistent with the medical evidence. In contrast, the recantations were implausible and appeared to be the product of intimidation or a desire for financial support from the accused, who was the family’s provider. The defense of mere touching was inconsistent with the victim’s initial detailed account of sexual intercourse and the corroborative medical findings. Therefore, the trial court and the Court of Appeals correctly convicted Teodoro of two counts of statutory rape, imposing the penalty of reclusion perpetua for each count and awarding civil indemnities.