G.R. Nos. 109396-97. July 17, 1996. PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROMEO OARGA y SISON, accused-appellant.
FACTS

The prosecution’s case established that on the evening of May 20, 1990, appellant Romeo Oarga, the live-in partner of complainant Lorelie Trinidad’s mother, woke the 11-year-old Lorelie while she was asleep. Armed with a fan-knife (balisong), he ordered her to remove her clothes, placed the knife beside her, and forcibly had carnal knowledge of her. He threatened her with the knife and bit her. Lorelie pleaded for him to stop but he ignored her. He warned her not to tell her mother. A second incident occurred on June 3, 1990, when Oarga isolated Lorelie from her siblings, turned off the lights, and raped her again in a similar manner. Lorelie eventually left home and later disclosed the assaults in a letter to her mother in December 1990. A medical examination confirmed loss of virginity. Two complaints for rape were filed. The Regional Trial Court convicted Oarga of two counts of rape and sentenced him to reclusion perpetua for each count, with damages.

ISSUE

Whether the trial court erred in convicting the accused-appellant of two counts of rape based on the credibility of the complainant’s testimony, despite the alleged lack of resistance or outcry during the incidents.

RULING

The Supreme Court affirmed the conviction. The legal logic is anchored on Article 335 of the Revised Penal Code, which defines rape. The Court emphasized that under paragraph 3 of this article, carnal knowledge of a woman under twelve years of age constitutes rape by statutory definition, “even though neither force, intimidation, nor the victim’s unconsciousness is present.” It was undisputed that Lorelie was under twelve at the time of both incidents, as evidenced by her birth certificate. Therefore, the mere fact of carnal knowledge was sufficient to establish the crime. The defense’s argument about the victim’s lack of struggle or shout became legally irrelevant under this statutory provision.
Nonetheless, the Court also found that force and intimidation were, in fact, present. Oarga, who stood in a position of moral dominance as a surrogate parent, used a balisong to threaten the young victim. Her testimony, which was clear and consistent, detailed the use of this weapon and the accompanying pain. This testimony was corroborated by the medical findings of vaginal lacerations, confirming penetration. The Court upheld the trial court’s assessment of the complainant’s credibility, noting the absence of any ill motive to falsely accuse the appellant and the inherent plausibility of a young victim’s submission due to fear and moral ascendancy of the aggressor. Thus, the conviction was sustained.