G.R. No. 132238 November 17, 1999
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. LITO BAYGAR y ESCOBAR, accused-appellant.

FACTS

The accused-appellant, Lito Baygar, was convicted by the Regional Trial Court of Antipolo for the rape of Joanna Kristin Nable, a five-year-old minor. The prosecution’s evidence established that on December 7, 1993, while Joanna was alone with Baygar, the family’s houseboy, in her grandmother’s room, he asked her to show her vagina and then exposed his penis. He then inserted his penis into her vagina twice while she was still wearing her panties. Joanna felt pain but did not cry. The incident was discovered by her grandmother, who later informed Joanna’s parents. The child was medically examined, with findings of genital congestion consistent with the application of pressure from a hard object like an erect penis, and a vaginal infection.
The defense presented a denial, with Baygar testifying that the charge was fabricated by Joanna’s parents to avoid paying him P5,000 in unpaid salary. He claimed he was arrested at their house upon their return from an outing. The trial court rejected this defense, finding it implausible that parents would subject their young daughter to the ordeal of medical exams and a public trial over a salary dispute. It gave credence to the victim’s categorical testimony of penetration despite some inconsistencies, noting her tender age.

ISSUE

Whether the guilt of the accused-appellant for the crime of rape was proven beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction. The Court emphasized that the credibility of the child victim’s testimony is paramount. Inconsistencies on minor details, such as the exact number of times the act was committed or the specific time, are inconsequential and even enhance credibility as they negate the possibility of rehearsed testimony. The core assertion of carnal knowledge remained consistent and unwavering. The Court found no ill motive for the child or her family to fabricate such a grave charge, noting the profound trauma and scandal associated with a rape case. A young child would not concoct a story of defloration and endure the invasive medical examinations and public trial unless it were true.
The medical findings, showing genital congestion, supported the claim of physical intrusion. Given the victim’s age of five years at the time of the crime, the case constitutes statutory rape under Article 335(3) of the Revised Penal Code. In statutory rape, carnal knowledge alone is sufficient to constitute the crime; proof of force, intimidation, or lack of consent is not required. The defense of frame-up due to unpaid wages was correctly dismissed as inherently unbelievable. The Court modified the damages, awarding an additional P50,000 as moral damages, which is automatically granted in rape cases due to the presumed psychological suffering. The penalty of reclusion perpetua and civil indemnity of P50,000 were sustained.