GR 135454; (November, 2001) (Digest)
G.R. Nos. 135454-56; November 13, 2001
PEOPLE OF THE PHILIPPINES, appellee, vs. RODERICK SANTOS y YAMAT, appellant.
FACTS
The appellant, Roderick Santos, was convicted by the Regional Trial Court of two counts of statutory rape and one count of acts of lasciviousness against Mila Bonifacio. The incidents occurred in 1993, 1994, and 1995, beginning when the victim was eight years old. The prosecution established that Santos, who lived nearby, raped the victim on two occasions and committed lascivious acts on another, each time employing force and intimidation. He threatened to kill her if she reported the assaults.
The victim did not immediately disclose the crimes due to fear. The case was filed only in October 1997 after she confided in a teacher, who then informed her father. The defense consisted of denial and alibi, claiming the charges were fabricated due to a land dispute. The trial court found the victim’s testimony credible and convicted Santos, sentencing him to reclusion perpetua for each rape and imprisonment for the lasciviousness.
ISSUE
The core issue is whether the victim’s credibility was impaired by the significant delay in reporting the rapes, and whether the prosecution proved the appellant’s guilt beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction. The delay in reporting, while considerable, was satisfactorily explained by the victim’s young age and the appellant’s death threats. The Court consistently holds that delay, especially when the victim is a minor, does not automatically undermine credibility if the reason is founded on fear or intimidation. The victim’s detailed and candid testimony, which remained consistent even under cross-examination, carried the hallmark of truth.
The defense of denial and alibi cannot prevail over the positive and categorical identification by the victim. No improper motive was shown for the victim to falsely accuse the appellant. The medical examination, while not conclusive due to the lapse of time, did not negate the commission of rape. The Court modified the awarded damages, granting P50,000 as civil indemnity and P25,000 as moral damages for each count of rape, and P30,000 for the acts of lasciviousness. The elements of statutory rape—carnal knowledge with a girl below twelve years of age—were conclusively proven.