G.R. No. 193666 February 19, 2014
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs. MARLON CASTILLO Y VALENCIA, Accused-Appellant

FACTS

The accused-appellant, Marlon Castillo y Valencia, was charged with two counts of qualified rape committed against his daughter, “Nene.” The first Information alleged acts, including rubbing his penis on the labia of her vagina, licking, and digital insertion, occurring between August 1996 and August 1997 when the victim was six years old. The second Information alleged similar acts of sexual assault in November 2000 when she was twelve. The victim testified that the abuse started when she was six, occurring multiple times, and that her father used threats and his parental authority to facilitate the acts. A medico-legal report showed an intact hymen. The accused-appellant denied the charges, claiming they were fabricated due to familial discord.
The Regional Trial Court convicted the accused-appellant of two counts of qualified rape under Article 266-A of the Revised Penal Code, as amended, sentencing him to reclusion perpetua for each count and awarding moral damages. The Court of Appeals affirmed the conviction but modified the damages. The accused-appellant appealed to the Supreme Court, arguing the prosecution failed to prove his guilt beyond reasonable doubt.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of the accused-appellant for two counts of qualified rape.

RULING

The Supreme Court denied the appeal and affirmed the conviction. The Court held that the victim’s credible and categorical testimony, which withstood rigorous cross-examination, was sufficient to establish the crimes. The Court emphasized that in rape cases, the testimony of the victim, if credible, is enough to sustain a conviction. The defense of denial and frame-up, being inherently weak, could not prevail over the positive identification and detailed narration of the victim.
On the legal sufficiency of the acts, the Court ruled that the accused-appellant’s actions constituted rape through sexual intercourse under Article 266-A(1). Jurisprudence establishes that the slightest penetration of the female organ, including contact with the labia, consummates rape. Full penetration or rupture of the hymen is not required. The acts of rubbing his penis against the labia of her vagina, as testified to by the victim for both incidents, therefore constituted carnal knowledge. The qualifying circumstance of the victim being under eighteen and the offender being her parent was duly proven, warranting the penalty of reclusion perpetua for each count. The Court also affirmed the awarded damages as consistent with prevailing jurisprudence.