G.R. No. 110111 October 26, 1999
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. SOTERO GARIGADI, accused-appellant.

FACTS

The accused-appellant, Sotero Garigadi, was convicted by the Regional Trial Court of Malolos, Bulacan, for the rape of six-year-old Gloridel Floro. The prosecution’s case relied primarily on the victim’s testimony. Gloridel recounted that on May 22, 1990, while looking for playmates at the appellant’s house, she was kissed, made to sit on his lap, and fondled. Appellant then made her lie on a bed, removed her panty, and inserted his penis into her vagina. She managed to escape when her maid called for her. This account was corroborated by the medical findings of Dr. Lea Dilag, who examined Gloridel and noted a swollen, infected vagina with a laceration at the seven o’clock position.
The defense presented a contrary version, anchored on denial. Appellant claimed he merely gave the child a fatherly hug and kiss. He challenged the credibility of the victim’s testimony, describing it as vague and inconsistent. He also assailed Dr. Dilag’s medical expertise and findings, highlighting that a subsequent NBI medico-legal report indicated an intact hymen. The defense argued that the initial municipal judge found no probable cause, though the provincial prosecutor later filed the rape information.

ISSUE

The core issue is whether the prosecution proved the appellant’s guilt for the crime of rape beyond reasonable doubt, particularly in light of the alleged inconsistencies in the victim’s testimony and the conflicting medical evidence.

RULING

The Supreme Court affirmed the conviction. The legal logic centered on the established jurisprudential principle that in rape cases, the testimony of the victim, if credible, is sufficient to sustain a conviction. The Court found the testimony of the six-year-old victim to be straightforward, candid, and spontaneous. It held that the testimony of a child victim is given full weight and credit, as youth and immaturity generally render them incapable of fabricating a charge of such gravity. The alleged inconsistencies pertained to minor details and did not undermine the core narrative of sexual violation.
Regarding the conflicting medical evidence, the Court ruled that the NBI report indicating an intact hymen is not conclusive proof that rape did not occur. Medical findings are merely corroborative and not indispensable to a rape conviction. The Court noted that an intact hymen does not preclude rape, as penetration sufficient to constitute carnal knowledge can occur without full hymenal rupture. Furthermore, the Court emphasized that the trial court’s assessment of witness credibility is accorded high respect. The penalty of reclusion perpetua and the indemnity of P50,000 were upheld. Additionally, moral damages of P50,000 were awarded to the victim, as such damages are automatically granted in rape cases.