G.R. No. 133477 January 21, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. BENJAMIN RAFALES, accused-appellant.
FACTS
The accused-appellant, Benjamin Rafales, was convicted by the Regional Trial Court of statutory rape and sentenced to reclusion perpetua. The information alleged that in November 1993, through force and intimidation, he had carnal knowledge of the victim, Rochelle Gabriel, an 11-year-old minor, against her will. Rochelle testified that Rafales, their neighbor, raped her on three separate occasions in November 1993 when she was ten years old. Each incident followed a similar pattern: Rafales would order her playmates to leave, undress her, lay on top of her, and insert his penis into her vagina, causing her pain. She did not immediately report the rapes due to Rafales’s threats to kill her and her family. She ran away from home and only disclosed the incidents in 1995 to a social worker after being confronted with rumors.
ISSUE
Whether the guilt of the accused-appellant for the crime of statutory rape was proven beyond reasonable doubt.
RULING
Yes. The Supreme Court affirmed the conviction. The Court emphasized that in statutory rape, where the victim is below twelve years of age, the prosecution need not prove force, intimidation, or lack of consent; it is sufficient to establish the age of the victim and the fact of sexual intercourse. Rochelle’s categorical and consistent testimony on the carnal acts meets this standard. The Court found her testimony credible, noting that the testimony of a child-victim is given full weight and credit. The delay in reporting the crime was sufficiently explained by the accused’s threats and her tender age, which naturally induces fear and silence. The medico-legal finding of an intact hymen does not negate rape, as full penetration of the vagina is not required; mere entry of the labia is sufficient. The defense of bare denial cannot prevail over the positive and credible identification by the victim. The penalty of reclusion perpetua was affirmed, and the civil indemnity was increased to P50,000.00 in line with prevailing jurisprudence.