G.R. No. 178318 ; January 15, 2010
People of the Philippines, Appellee, vs. Edgardo Estrada, Appellant.

FACTS

Two Informations were filed on November 19, 1997, charging appellant Edgardo Estrada with two counts of Rape committed in July 1997 in Atimonan, Quezon. The victim, “AAA,” was 12 years old, and the appellant was her paternal uncle. “AAA” testified that the first rape occurred while she was sleeping beside the appellant in her grandmother’s house; he used force by pinning her hands. The second rape occurred at her grandfather’s house, where the appellant poked a knife at her. The prosecution presented “AAA’s” Birth Certificate to prove her minority. The appellant denied the charges, claiming alibi and that the charges were filed because “AAA” resented his advice. The defense also presented Irene, the grandmother of “AAA” and mother of the appellant, who testified she was unaware of any incident but admitted loving her son more.

ISSUE

Whether the appellant is guilty beyond reasonable doubt of the crime of rape.

RULING

The Supreme Court affirmed the modified Decision of the Court of Appeals. The appellant is found guilty of two counts of simple rape. The penalty is reclusion perpetua for each count. The appellant is ordered to pay ₱50,000.00 as civil indemnity, ₱50,000.00 as moral damages, and ₱30,000.00 as exemplary damages for each count of rape. The Court upheld the factual findings of the lower courts, giving great weight to the credible, straightforward, and categorical testimony of the victim, which was corroborated by medical findings of hymenal lacerations. The defenses of denial and alibi were rejected for being weak and uncorroborated. However, the qualifying circumstance of relationship was not sufficiently alleged in the Information (it merely stated “uncle” without specifying the degree of consanguinity), thus the conviction was for simple rape, not qualified rape. The victim’s minority was established but, absent proper allegation of relationship, could not qualify the crime.