GR 243625; (December, 2020) (Digest)

G.R. No. 243625, December 02, 2020
People of the Philippines, Plaintiff-Appellee, vs. Jeffrey Dereco y Hayag, Accused-Appellant.

FACTS

An Information dated September 1, 2009, charged accused-appellant Jeffrey Dereco y Hayag with the special complex crime of Robbery with Rape. The prosecution alleged that on August 26, 2009, in Quezon City, accused-appellant and an accomplice, alias “Biboy,” robbed the victim, AAA, of her cellphone, ring, and cash. On the occasion of the robbery, they both successively raped her through force and intimidation, with accused-appellant using a knife. AAA reported the incident, underwent a medico-legal examination, and later positively identified accused-appellant, who was arrested on August 29, 2009. The Medico-Legal Report (No. SC-35-2009) indicated a deep healed hymenal laceration and the presence of spermatozoa. The defense consisted solely of accused-appellant’s denial and alibi, claiming he was driving his pedicab at the time and was falsely identified after his arrest.

ISSUE

Whether the Court of Appeals erred in affirming accused-appellant’s conviction for rape, despite his arguments regarding the alleged inconsistencies and incredibility of the victim’s testimony, its contradiction by physical evidence, and the disregard of his defense of alibi and denial.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the conviction. The Court upheld the findings of the trial court and the Court of Appeals, giving great weight to their assessment of AAA’s credibility, as trial courts are in the best position to observe witness deportment. The Court found AAA’s testimony to be clear, consistent, and credible in detailing the rape. The medico-legal findings corroborated her account of sexual assault. The defense of alibi and denial could not prevail over the positive identification by the victim and the corroborative evidence. The special complex crime of Robbery with Rape was not proven due to the prosecution’s failure to establish all its elements; however, the conviction for the separate crime of rape under Article 266-A of the Revised Penal Code was sustained. The penalty of reclusion perpetua was imposed. The Court modified the damages in line with prevailing jurisprudence, ordering accused-appellant to pay AAA P75,000.00 as civil indemnity, P75,000.00 as moral damages, and P75,000.00 as exemplary damages, all with interest at 6% per annum from the finality of the judgment until fully paid.