GR 233867; (February, 2022) (Digest)
G.R. No. 233867 . February 28, 2022.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. XXX, ACCUSED-APPELLANT.
FACTS
The accused-appellant, a stay-in family driver, was charged with three counts of rape against the 14-year-old minor, AAA. In Criminal Case No. 07-146, for rape through sexual assault, it was alleged that on August 23, 2006, he inserted his finger into AAA’s vagina. In Criminal Case No. 07-147, for rape through sexual intercourse, it was alleged that on August 26, 2006, he had carnal knowledge of AAA. In Criminal Case No. 06-809, for rape through sexual assault, it was alleged that on September 2, 2006, he again inserted his finger into AAA’s vagina. The prosecution presented AAA’s testimony detailing the incidents, where the accused-appellant entered her room at night, used force and intimidation, and threatened to kill her and her family if she told anyone. For the third incident, the nursemaid CCC testified that she found the accused-appellant inside the locked room of AAA and BBB in the early morning. A medical examination revealed deep healed lacerations on AAA’s hymen. The defense was a denial, claiming he was asleep during the first two incidents and that he was merely checking on AAA’s asthma condition during the third. The Regional Trial Court found the accused-appellant guilty beyond reasonable doubt on all charges. The Court of Appeals affirmed the RTC decision with modifications. The case was elevated to the Supreme Court on appeal.
ISSUE
Whether the Court of Appeals correctly affirmed the conviction of the accused-appellant for two counts of rape through sexual assault and one count of rape through sexual intercourse.
RULING
The Supreme Court denied the appeal and affirmed the findings of the lower courts. The Court held that the testimony of the victim, AAA, was credible, straightforward, and consistent. The medical findings corroborated her claim of sexual intercourse. The defense of denial cannot prevail over the positive and categorical testimony of the victim. The Court found no reason to deviate from the factual findings of the trial court, which are accorded great weight and respect. The accused-appellant was found guilty beyond reasonable doubt of the crimes charged. The Court modified the awards of damages in accordance with prevailing jurisprudence.