G.R. Nos. 102773-77 June 8, 1993
People of the Philippines, plaintiff-appellee, vs. Godofredo Sayat, alias “Bobby” or “Buboy,” accused-appellant.

FACTS

Accused-appellant Godofredo Sayat was charged with five counts of rape in five separate criminal complaints subscribed by eight-year-old Marites Sayat. The complaints alleged that on August 28, 29, 30, 31, and September 1, 1990, in Pasig, Metro Manila, the accused, by means of threat, willfully had carnal knowledge of the complainant, a minor, against her will and consent. Appellant pleaded not guilty. After a consolidated trial, the Regional Trial Court found him guilty beyond reasonable doubt of five counts of rape, penalized under Article 335(3) of the Revised Penal Code, with the aggravating circumstance of relationship. He was sentenced to five penalties of reclusion perpetua, ordered to indemnify the victim P30,000.00, and to pay costs.
The prosecution’s version, anchored on the testimony of Marites Sayat, established that appellant, her half-brother 18 years her senior, raped her on five successive days in August and September 1990 in their house. He threatened to kill her if she disclosed the incidents. On September 1, 1990, a relative, Maribel Halino, saw Marites trembling after coming from the newly constructed house with appellant. When Marites’ mother returned from abroad in November 1990, she was informed, and Marites divulged the rapes. A medical examination by Dr. Emmanuel L. Aranas on November 23, 1990, revealed a healed hymenal laceration, consistent with the alleged acts.
In his defense, appellant alleged that during the dates in question, he was staying with his common-law wife in Sampaloc, Manila, and did not return to the Pasig house until two weeks later.

ISSUE

Whether the trial court erred in finding accused-appellant Godofredo Sayat guilty beyond reasonable doubt of the crime of rape.

RULING

The Supreme Court affirmed the trial court’s judgment, finding no compelling reason to disturb its factual findings and conclusion. The Court held that appellant’s guilt was proven by clear and convincing evidence. The testimony of the victim, Marites Sayat, who was eight years old at the time of the crimes, was simple, spontaneous, straightforward, and credible. The crime committed was statutory rape under Article 335(3) of the Revised Penal Code, where carnal knowledge of a woman below twelve years of age is punishable, and neither force nor resistance is an element. The law presumes the victim, due to tender years, incapable of legal consent. The medical findings corroborated the victim’s account. The defense of alibi was weak and uncorroborated. The Court also noted that the relationship as half-siblings was sufficiently established through the victim’s testimony as a declaration of pedigree. However, the Court increased the award of moral damages from P30,000.00 to P50,000.00 in line with jurisprudential policy for rape cases indicating greater perversity. Except for this increased award, the judgment was affirmed.