G.R. No. 137843; October 12, 2001
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EDUARDO AÑONUEVO y DELOS SANTOS, accused-appellant.

FACTS

The accused, Eduardo Añonuevo, was charged with the rape of his common-law wife’s 13-year-old daughter, Analyn Evangelista. The prosecution evidence established that on September 12, 1997, in San Jose del Monte, Bulacan, the accused arrived home smelling of liquor while Analyn was alone and sleeping. He threatened her with a fan knife, ordered her not to shout, and forcibly had carnal knowledge of her. Analyn immediately reported the incident to a neighbor and then to the police, executing a sworn statement. Medical examination revealed genital abrasions and congestion consistent with recent trauma. The defense consisted solely of the accused’s denial and alibi, claiming he was at work and that Analyn fabricated the charge due to anger over his planned marriage to her mother.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused for the crime of rape beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The Court found Analyn’s testimony to be credible, straightforward, and consistent. She provided a detailed account of the assault, including the use of a fan knife and the specific sexual acts, which remained unshaken during cross-examination. Her immediate reporting of the crime to a neighbor and the police, corroborated by her sworn statement and the medico-legal findings, bolstered her credibility. The medical evidence, while noting an intact hymen, confirmed the presence of recent abrasions and congestion in her genitalia, which the medico-legal officer opined could be caused by traumatic manipulation, consistent with her account of a forcible sexual act. The Court emphasized that an intact hymen does not negate rape, as full penetration of the vagina is not required; mere entry of the labia is sufficient. The accused’s denial and imputation of ill motive were deemed weak defenses that could not prevail over the positive and credible identification by the victim. The qualifying circumstance of the victim’s minority (13 years old) and the aggravating circumstance of dwelling were correctly appreciated. The Court modified the damages awarded, increasing civil indemnity and moral damages to P75,000.00 each and awarding P25,000.00 as exemplary damages due to the presence of aggravating circumstances.