G.R. No. 113057 -58 May 29, 1995
PEOPLE OF THE PHILIPPINES, plaintiff-appellee vs. JUAN REMOTO Y FAJELA @ JOHNNY, accused-appellant.

FACTS

Accused-appellant Juan Remoto was charged with two counts of rape against six-year-old girls, Leslie Santos and Carabella Viray, in Mariveles, Bataan. In December 1989, Remoto, who was tasked to bring Leslie to and from school, lured her with coins to a church grounds, bent her over, and sexually assaulted her. He threatened her to keep silent. In April 1991, during a brownout, Remoto lured Carabella with a promise of candy, brought her to a neighbor’s house, and raped her on a bed. Her ten-year-old sister, Brendalyn, witnessed the act, seeing Remoto on top of a naked Carabella. Remoto fled upon being seen. Both victims initially remained silent out of fear.
The crimes were discovered in January 1992 when the two girls were overheard discussing the incidents during a party. Their parents were informed, leading to medical examinations and the filing of criminal complaints. The trial court convicted Remoto of two counts of rape and sentenced him to reclusion perpetua for each count. He appealed, questioning the credibility of the child witnesses.

ISSUE

Whether the testimonies of the child victims are credible and sufficient to sustain the conviction of the accused-appellant for two counts of rape beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The Court emphasized that the testimonies of child victims are given full weight and credit. At their tender age of six, they are presumed incapable of fabricating a charge of rape or of being motivated by malice. The detailed and consistent narrations of both Leslie and Carabella, describing the pain they felt and the specific acts of sexual assault, were found credible and convincing. The Court noted that their initial silence, induced by the accused’s threats, is typical behavior for child victims and does not undermine their credibility.
The defense of denial and alibi proffered by the appellant was rejected as inherently weak. It could not overcome the positive identification and categorical testimonies of the victims. The Court also found the testimony of the eyewitness, Brendalyn Viray, who saw the appellant on top of her sister, to be credible and corroborative. The medical certificates, while not showing fresh lacerations due to the significant lapse of time, were consistent with the victims’ accounts. The totality of the evidence established the appellant’s guilt beyond reasonable doubt for both counts of rape.