G.R. No. 131516 ; March 5, 2003
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RONNIE RULLEPA Y GUINTO, accused-appellant.

FACTS

Accused-appellant Ronnie Rullepa, the houseboy of the Buenafe family, was charged with the rape of three-and-a-half-year-old Cyra May Buenafe. The prosecution established that on November 20, 1995, Cyra May told her mother, Gloria, that “Kuya Ronnie” had inserted his penis into her vagina, anus, and mouth on multiple occasions. When confronted by Gloria and her husband that same night, Rullepa admitted to the acts but claimed it happened only once on November 17, 1995. The child’s testimony in court corroborated her initial disclosure. A medico-legal examination revealed abrasions on Cyra May’s labia minora, which the doctor opined could have been caused by friction from an object like an erect penis, though the hymen remained intact.
The defense presented only Rullepa, who denied the accusations. He claimed the abrasions were from a pre-existing urinary condition for which he was sent to buy medicine. He alleged the complaint was fabricated by Gloria after he refused to answer her queries about her husband’s alleged womanizing. The trial court convicted Rullepa of rape and imposed the death penalty, prompting an automatic review.

ISSUE

The core issue is whether the prosecution proved Rullepa’s guilt for rape beyond reasonable doubt, particularly considering the admissibility and weight of his alleged extrajudicial admission and the sufficiency of the evidence.

RULING

The Supreme Court affirmed the conviction but modified the penalty to reclusion perpetua. The Court found the guilt of the accused proven beyond reasonable doubt. The trial court correctly considered Rullepa’s admission to the child’s parents. While an extrajudicial confession made to a private individual without counsel is inadmissible, a mere admission of a fact not directly constituting guilt is admissible. Rullepa’s statement admitting the sexual act but limiting it to one occurrence was an admission of a fact (the carnal knowledge) that did not, by itself, constitute a confession to the crime of rape, which requires force or intimidation. Thus, it was properly admitted as circumstantial evidence. This admission, coupled with the credible and spontaneous testimony of the child victim and the corroborative medical findings, formed an unbroken chain leading to a fair and reasonable conclusion of guilt. The Court, however, reduced the penalty to reclusion perpetua because the information failed to allege the victim’s exact age (only “3 years of age, a minor”) and her relationship to the offender with the requisite specificity to justify the death penalty under the applicable law.