GR 116732; (April, 1997) (Digest)
G.R. No. 116732 April 2, 1997
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RENE C. HENSON, accused-appellant.
FACTS
On June 16, 1993, six-year-old Mae Chille Aguilar went to the house of her neighbor, accused-appellant Rene C. Henson, in Bacolod City. Henson led her to his bedroom, made her lie down, and removed her shorts and underwear. He then unzipped his pants, went on top of her, and made up-and-down movements, causing her pain. Afterward, the victim dressed and left. Her cousin, ten-year-old Analyn Aguilar, who resided in the same house, testified that she heard strange sounds, peeped through a hole in a plywood wall, and witnessed Henson on top of Mae Chille. Analyn and another cousin reported the incident to their grandfather and the victim’s mother, Myrna Aguilar, who subsequently filed a complaint. Medical examination revealed abrasions on the victim’s genitalia and thigh, consistent with an attempted forcible entry, though her hymen remained intact.
The defense presented an alibi. Henson claimed he was at an Iglesia ni Kristo church meeting from around 5:20 PM until the next morning, supported by testimonies from a security guard and a church member. He also alleged the accusation stemmed from a grudge held by the victim’s mother and Analyn. The Regional Trial Court convicted Henson of statutory rape and sentenced him to reclusion perpetua, with damages.
ISSUE
Whether the accused-appellant is guilty beyond reasonable doubt of the crime of statutory rape.
RULING
Yes, the Supreme Court affirmed the conviction. The Court found the testimonies of the child victim, Mae Chille, and her young cousin, Analyn, to be credible, consistent, and given in a straightforward manner. The medical findings, while indicating no full penetration, corroborated the attempted carnal knowledge by showing abrasions caused by a forcible attempt. In statutory rape under Article 335(3) of the Revised Penal Code, carnal knowledge with a girl under twelve years of age is punishable; full penetration is not required, and the victim’s consent is immaterial. The defense of alibi was inherently weak and could not prevail over the positive identification by credible witnesses. The Court also noted the improbability of a mother fabricating such a grave charge and subjecting her young daughter to the ordeal of a public trial without a genuine motive for justice. Thus, the prosecution successfully proved Henson’s guilt beyond reasonable doubt.