G.R. No. 127878; July 25, 2003
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. MAURO DE JESUS y MAGNAYE, Accused-Appellant.

FACTS

The accused-appellant, Mauro de Jesus, was convicted by the Regional Trial Court of statutory rape against his daughter, Ma. Cristina de Jesus. The Information alleged that the crime was committed in July 1990 when the victim was five years old. During trial, the prosecution presented the victim, who testified that when she was two years old, her father inserted his finger and later his penis into her vagina on multiple occasions while she was sleeping, usually when her mother was absent. The victim’s mother, Amelita Murillo, testified to observing similar abusive behavior towards all her daughters and reported the incidents after years of silence. A medical examination revealed the victim was in a non-virgin state.
The defense presented a denial, claiming the charges were fabrications by his estranged common-law wife, Amelita, due to marital discord. Appellant asserted he loved his children and that the testimony was coerced. His father corroborated this, portraying Amelita as abusive. The defense also questioned the credibility of the victim’s memory of events from age two.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused for statutory rape beyond reasonable doubt, particularly considering the victim’s age at the time of the alleged acts and the credibility of her testimony.

RULING

The Supreme Court affirmed the conviction. The Court held that a victim’s testimony, especially in rape cases, is given full weight and credit when credible. The victim’s detailed and candid account of the sexual assaults, delivered in a straightforward manner, was deemed credible and sufficient to establish the crime. The Court rejected the defense’s argument regarding “infantile amnesia,” noting that while very early childhood memories are often not retained, traumatic events can form lasting impressions. The medical findings, though not conclusive of recent rape, corroborated the loss of virginity and were consistent with the victim’s account of abuse that occurred years prior.
The defense of denial and imputation of ill motive on the part of the mother cannot prevail over the positive and credible testimony of the victim. The Court emphasized that testimonies of child victims are given utmost credence. The delay in reporting was sufficiently explained by the mother’s fear and desire to keep the family intact, which does not undermine the veracity of the charge. All elements of statutory rape were proven: sexual intercourse with a girl under twelve years of age. The accused, as the father, had moral ascendancy and the opportunity to commit the crime. Thus, the trial court’s decision was upheld.