GR 116596; (March, 1997) (Digest)
G.R. Nos. 116596-98 March 13, 1997
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. LORENZO TOPAGUEN alias “APIAT,” accused-appellant.
FACTS
Accused-appellant Lorenzo Topaguen was convicted of three counts of rape against nine-year-old victims April Maglanga, Maura Galasa, and Fraulein Grail Sawad. The prosecution evidence established that on December 15, 1990, in Bontoc, Mountain Province, Topaguen lured the girls to his house, threatened them with a knife, and successively raped them. The victims’ testimonies were corroborated by medical examinations conducted by Dr. Elaine Fagsao, which confirmed recent hymenal lacerations and physical injuries consistent with sexual assault. The defense presented an alibi, claiming Topaguen was asleep due to intoxication and later suspected the children of stealing his money, suggesting the charges were fabricated due to familial discord over property.
ISSUE
The core issue is whether the trial court erred in convicting the accused based on the credibility of the child victims’ testimonies and the medical evidence, despite the defense’s challenges to their consistency and the physician’s expertise.
RULING
The Supreme Court affirmed the conviction. The legal logic centered on the well-entrenched doctrine that the testimonies of child victims, when credible and consistent on material points, are sufficient to sustain a conviction for rape. Minor inconsistencies in their narrations do not undermine credibility but may even indicate truthfulness, as they are natural for young witnesses subjected to rigorous questioning. The Court emphasized that the victims’ detailed account of the sequential rape, their tender age, and the immediate reporting to a parent corroborated their credibility.
Regarding the medical evidence, the Court ruled that the defense failed to rebut the presumption that the hymenal lacerations were caused by sexual intercourse. While the accused questioned Dr. Fagsao’s experience, he relied on her findings to argue alternative causes for the injuries—a contradictory stance that did not meet his burden of proof. The defense’s alibi and motive of property dispute were deemed weak and unsubstantiated compared to the positive identification by the victims. The Court also dismissed the claim that the accused’s age (56) precluded the act, noting that age alone does not determine sexual capability. Thus, the trial court’s assessment of evidence was upheld, and the indemnity for each victim was increased to P50,000.00 in line with prevailing jurisprudence.