G.R. No. 194833 , July 2, 2014
People of the Philippines, Plaintiff-Appellee, vs. Porferio Balino alias “Toto,” Accused-Appellant.

FACTS

Porferio Balino was charged with statutory rape for an incident in August 2001 in Dangcagan, Bukidnon. The victim, AAA, was eight years old at the time. AAA testified that she was watching TV at the accused’s house. After the show, the accused pulled her inside, closed the doors, brought her to a room, undressed her and himself, and had sexual intercourse with her. She felt pain and bled. The accused threatened to kill her if she revealed the incident. AAA’s mother, BBB, discovered the assault when AAA was hospitalized in September 2001 for a fever and swelling vagina. A doctor confirmed AAA had been molested. The accused denied the allegations, claiming an altercation with AAA’s father had stopped her from visiting his house. The Regional Trial Court (RTC) found Balino guilty, a decision affirmed by the Court of Appeals (CA).

ISSUE

Whether the Court of Appeals erred in affirming the RTC’s conviction of Porferio Balino for statutory rape based on the credibility of the victim’s testimony.

RULING

The Supreme Court denied the appeal and affirmed the conviction, modifying only the damages awarded. The Court upheld the findings of the RTC and CA, emphasizing the trial court’s superior position to assess witness credibility. The testimony of the young victim was found to be straightforward, convincing, and consistent. Inconsistencies, if any, were on trivial matters and did not affect the core fact of rape. The defense of denial and alibi was deemed weak against the victim’s positive identification. The Court sustained the penalty of reclusion perpetua but modified the civil indemnity and moral damages to ₱75,000.00 each and exemplary damages to ₱75,000.00, in line with prevailing jurisprudence.