G.R. No. 246975. March 23, 2022.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. XYZ, ACCUSED-APPELLANT.
FACTS
The accused-appellant, XYZ, was charged with three counts of Rape under Article 266-A of the Revised Penal Code, as amended, against AAA, a 15-year-old minor. The Informations alleged: (1) on December 23, 2013, accused-appellant had carnal knowledge of AAA (Criminal Case No. 616-M-2014); (2) on January 3, 2014, he inserted his finger into her vagina (Criminal Case No. 617-M-2014); and (3) on January 16, 2014, he again inserted his finger into her vagina (Criminal Case No. 618-M-2014). The prosecution’s version established that on December 23, 2013, accused-appellant, the common-law husband of AAA’s sister, forced AAA to lie down in a bedroom, lifted her skirt, pulled down her panties, and inserted his penis into her vagina, threatening her not to tell anyone. On January 3 and 16, 2014, while AAA was asleep, accused-appellant lay beside her and inserted his finger into her vagina. AAA eventually reported the incidents to her mother and sister. The defense denied the charges, presenting alibis for the dates in question and claiming AAA fabricated the charges due to resentment. The Regional Trial Court (RTC) convicted accused-appellant for the December 23, 2013 incident (Criminal Case No. 616-M-2014) but acquitted him for the January 2014 incidents, finding the elements of force, violence, and intimidation wanting for those charges. The Court of Appeals (CA) affirmed the RTC’s conviction but modified the damages awarded. Accused-appellant appealed, arguing inconsistencies in AAA’s testimony, her failure to immediately report the first incident, and the absence of genital injuries in the medico-legal report.
ISSUE
Whether the Court of Appeals correctly affirmed accused-appellant’s conviction for Rape in Criminal Case No. 616-M-2014.
RULING
Yes, the Court of Appeals correctly affirmed the conviction. The Supreme Court found no compelling reason to depart from the uniform factual findings of the RTC and CA, which are accorded respect and finality on matters of witness credibility. The prosecution proved all elements of Rape under Article 266-A beyond reasonable doubt for the December 23, 2013 incident. AAA’s testimony was credible, consistent, and categorical. The alleged inconsistencies between her sworn statement and court testimony (regarding accused-appellant’s attire and her sister’s presence) were minor and did not affect her core assertion of being raped. The failure to immediately report the rape is not unusual for a young victim threatened by her abuser, who was a relative with moral ascendancy. The absence of fresh hymenal lacerations does not negate rape, as medical findings are not indispensable for conviction. The defense of denial and alibi, being weak and self-serving, cannot prevail over the positive identification by the victim. The Court affirmed the penalty of reclusion perpetua and, following prevailing jurisprudence, increased the awards of civil indemnity, moral damages, and exemplary damages to P75,000.00 each, with 6% per annum interest from finality until fully paid. The appeal was dismissed.