G.R. No. 127846 ; October 18, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROLANDO SANTOS Y GARCIA also known as Ole, accused-appellant.

FACTS

Accused-appellant Rolando Santos was charged with the rape of Cindy de la Cruz, an eight-year-old minor, on or about May 10, 1992. The prosecution alleged that while Cindy was watching television, Santos brought her to a bathroom, undressed her, and had carnal knowledge of her. The assault was interrupted by a knock on the door from Cindy’s sister. Cindy immediately reported the incident to her aunt and parents, leading to a medico-legal examination. Dr. Marcial Ceñido testified that Cindy’s hymen was intact but showed marked reddening, which could result from traumatic pressure like that from a penis or finger.
The defense consisted of denial and an imputation of improper motive. Santos claimed the charge was fabricated by Cindy’s mother, Myrna, because she had allegedly discovered her husband embracing Santos. He testified that Myrna had offered to settle the case for money, a claim Myrna vehemently denied. The trial court found the testimony of the young victim clear and credible, while characterizing the accused’s testimony as erratic and evasive, and convicted Santos of rape under Article 335, paragraph 3 of the Revised Penal Code, sentencing him to reclusion perpetua.

ISSUE

Whether the accused-appellant is guilty of rape beyond reasonable doubt, considering the victim’s intact hymen and the defense of denial and alleged improper motive.

RULING

The Supreme Court affirmed the conviction. The Court explained that the intact state of the hymen does not negate rape. Jurisprudence establishes that rape can be consummated even with the slightest penetration of the labia of the female organ; full penetration or hymenal laceration is not required. The medico-legal findings of reddening were consistent with traumatic pressure, supporting the victim’s account. The Court gave full credence to the straightforward testimony of the child victim, which was consistent and given in a categorical manner. The defense of denial is inherently weak and cannot prevail over the positive identification by the complainant. The alleged vengeful motive of the mother was not substantiated and did not discredit the victim’s own clear narration of the crime. Since the victim was under twelve years of age at the time of the offense, even the absence of force or intimidation is immaterial under the applicable law, Article 335(3) of the Revised Penal Code. The penalty of reclusion perpetua was thus affirmed, and moral damages were awarded to the victim.