PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. JOSELITO BAGUIO y SANTOS, Accused-Appellant. G.R. No. 250875, June 28, 2021.

FACTS:
Accused-appellant Joselito Baguio y Santos was charged with the crime of Rape under Article 266-A of the Revised Penal Code. The prosecution’s case relied primarily on the testimony of the private complainant, AAA, who was 13 years old at the time of the alleged incident. AAA testified that Baguio, a neighbor, forcibly had sexual intercourse with her inside his house. The defense interposed denial and alibi, claiming Baguio was elsewhere during the alleged rape. The Regional Trial Court convicted Baguio of Qualified Rape, imposing the penalty of reclusion perpetua without eligibility for parole and awarding damages. The Court of Appeals affirmed the conviction. Baguio appealed to the Supreme Court, arguing that the prosecution failed to prove his guilt beyond reasonable doubt, citing inconsistencies in AAA’s testimony and the lack of medical evidence.

ISSUE

Whether the Court of Appeals erred in affirming accused-appellant’s conviction for Qualified Rape, despite alleged inconsistencies in the victim’s testimony and the absence of medical evidence.

RULING

NO, the Court of Appeals did not err. The Supreme Court AFFIRMED the conviction.

The Court held that the alleged inconsistencies in AAA’s testimony pertained to minor and trivial details that did not affect the core elements of the crime. Inconsistencies on minor matters may even enhance a witness’s credibility by negating any suspicion of rehearsed testimony. The essential elements of rape through sexual intercourse under Article 266-A were sufficiently proven: (1) that accused-appellant had carnal knowledge of AAA; and (2) that such act was accomplished through force, threat, or intimidation. AAA’s categorical, positive, and straightforward testimony on the fact of forced sexual intercourse was credible and sufficient to sustain a conviction.

Regarding the lack of medical evidence, the Court reiterated the settled doctrine that medical examination is not indispensable in a prosecution for rape. A victim’s testimony alone, if credible, is sufficient to convict. The Court emphasized that rape is a highly personal offense, often leaving no physical evidence, especially when committed against a child. The qualifying circumstance of minority (AAA being under 18) and her relationship to the offender as a neighbor (not a relative within the degrees that would qualify under Article 266-B) were properly considered. However, the Supreme Court modified the nomenclature of the crime from “Qualified Rape” under Article 266-B to Simple Rape under Article 266-A, as the qualifying circumstance of relationship under Article 266-B did not apply. The penalty of *reclusion perpetua* without parole was correctly imposed pursuant to Republic Act No. 9346 , and the awarded damages were affirmed with modifications in accordance with prevailing jurisprudence.