G.R. No. 131203 , August 2, 2001
People of the Philippines, plaintiff-appellee, vs. Guillermo Cariño, accused-appellant.

FACTS

Accused-appellant Guillermo Cariño was charged with the rape of his granddaughter, Maryann Cariño, in January 1990 in Jones, Isabela. The information alleged the rape was committed by means of force, intimidation, and lewd designs. At the time, Maryann was 13 years old and lived with her father, siblings, and appellant. Her parents were often away. The prosecution evidence showed that one night in January 1990, appellant entered Maryann’s room armed with a knife, threatened to kill her, and had carnal knowledge of her. Her aunts, Virgielyn Juan and Siony Cariño, overheard the incident from beneath the house but did not report it out of fear, as appellant had a violent history. Appellant repeatedly raped Maryann thereafter. She reported the rapes to her father in 1995 and filed a complaint. A medical examination revealed a “ruptured hymen.” Appellant denied the charge, claiming he was too old and incapable. The Regional Trial Court found him guilty and initially sentenced him to death, but later reduced it to reclusion perpetua upon noting the crime occurred before the effectivity of the death penalty law ( R.A. No. 7659 ).

ISSUE

Whether the trial court erred in giving credence to the testimonies of the private complainant and the prosecution witnesses despite alleged inconsistencies.

RULING

The Supreme Court found no error. The perceived discrepancies in Maryann’s testimony regarding the time (night vs. daytime) and place (inside the house vs. inside a hut) of the first rape do not destroy her credibility. Such inconsistencies are understandable for a young, traumatized victim recalling painful events and are not essential elements of the crime. Her testimony was straightforward, spontaneous, and candid. No motive was shown for her to falsely accuse her grandfather. The testimonies of her aunts, who overheard the incident, corroborated her account, and their initial silence was justified by their reasonable fear of appellant. Appellant’s defense of denial cannot prevail over the positive identification and credible testimony of the victim. The Court affirmed the conviction for rape and the penalty of reclusion perpetua, as well as the award of moral damages.