G.R. No. 133441; November 29, 2000
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROMMEL PINE y GARCIA, accused-appellant.

FACTS

The prosecution established that on April 30, 1997, in San Juan, Metro Manila, ten-year-old Roxanne Pedro was watching television in her employer’s playroom with the houseboy, accused-appellant Rommel Pine, and another helper. After the other helper left, Pine forced Roxanne to lie down, held her by the shoulder, and pulled down her shorts. He then had sexual intercourse with her while covering her mouth to prevent her from screaming. He later warned her not to tell anyone. The crime was discovered on May 17, 1997, when Roxanne’s mother saw her with her shorts pulled down in Pine’s presence. Roxanne later confessed the rape to her mother. A medico-legal examination confirmed a deep, healed hymenal laceration consistent with sexual intercourse occurring approximately three weeks prior.
Accused-appellant denied the allegations, claiming that on the evening in question, Roxanne, her mother, and the other helper were all present in the playroom before everyone went to sleep separately. He asserted that he had no motive to commit the crime and described his relationship with the child as affectionate. The Regional Trial Court convicted him of rape and sentenced him to reclusion perpetua, ordering him to pay ₱200,000 in moral damages.

ISSUE

Whether the trial court erred in convicting accused-appellant of rape based on the victim’s testimony and the medical findings.

RULING

The Supreme Court affirmed the conviction but modified the damages. The Court upheld the trial court’s assessment of the victim’s credibility, noting that inconsistencies in her testimony regarding minor details did not undermine the core narrative of the rape. The Court emphasized that in rape cases, the testimony of a victim, especially a child, is given full weight and credit when she remains consistent on the essential fact of violation. The medical findings, which showed a deep, healed laceration, corroborated her account. The Court also ruled that the force and intimidation required in rape are relative; given the victim’s age of ten and the accused’s position as a trusted adult in the household, his physical restraint and covering of her mouth constituted sufficient force and intimidation to subdue her will. The failure to immediately report the crime was reasonably explained by her fear and the accused’s threats.
Regarding the penalty, reclusion perpetua was proper as the rape was committed through force and intimidation and the victim was under twelve years old. However, the Court reduced the moral damages from ₱200,000 to ₱50,000 in line with prevailing jurisprudence and awarded an additional ₱50,000 as civil indemnity, which is mandatory upon proof of rape. The decision was affirmed with modifications to the awarded damages.