G.R. No. 138959 . October 19, 2000.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DANILO OSING y BIEN, accused-appellant.

FACTS

Accused-appellant Danilo Osing was convicted of rape by the Regional Trial Court and sentenced to reclusion perpetua. The Information alleged that on October 24, 1997, in Las Piñas City, he had carnal knowledge of eight-year-old Jeremea R. Bautista through force and intimidation. The prosecution presented Jeremea, who testified that her neighbor, the accused, dragged her into a vacant house, undressed her, and inserted his penis into her vagina. She informed her mother, leading to a barangay report and his apprehension. Dr. Emmanuel Aranas, a medico-legal officer, testified that his examination revealed a healed, shallow hymenal laceration consistent with penile insertion, noting the victim was in a non-virgin state but bore no external signs of physical force.
The defense presented only accused-appellant, who denied the charge. He claimed the accusation was fabricated by the victim’s father due to a prior altercation during a drinking spree. The trial court found the prosecution’s evidence credible and rendered a verdict of guilt.

ISSUE

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

RULING

Yes, the Supreme Court affirmed the conviction with modification on damages. The Court upheld the trial court’s assessment of the victim’s credibility. It ruled that minor inconsistencies in the testimony of an eight-year-old child, traumatized by a harrowing experience, do not undermine her credibility but may even reinforce it, as error-free recall cannot be expected. The testimony of a rape victim, if credible, is sufficient to sustain a conviction even without corroboration.
The Court rejected the defense of denial and alleged fabrication. It emphasized that it is unnatural for parents to subject a child to the shame and ordeal of a rape case merely to settle a grudge. Furthermore, the medico-legal finding of no external injuries does not negate rape, as proof of physical injury is not an essential element. Critically, the case involved statutory rape, as the victim was proven to be eight years old via her birth certificate. In statutory rape, carnal knowledge of a girl below twelve years old is punishable, and proof of force or intimidation becomes unnecessary. The fact of intercourse, as established by the victim’s categorical testimony and supported by medical findings, was sufficiently proven. The penalty of reclusion perpetua was affirmed. Civil indemnity was increased to P50,000.00, and moral damages were likewise increased to P50,000.00, in accordance with prevailing jurisprudence.