G.R. No. 139314 ; June 6, 2002
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MOISES MANRIQUE Y BALLENA, accused-appellant.

FACTS

The prosecution’s evidence established that on March 8, 1998, in Canaman, Camarines Sur, the 10-year-old victim, Lorna de Belen, was playing near a guava tree when accused-appellant Moises Manrique approached. After her playmates left, appellant dragged her to his house, threatened to kill her if she made noise, and forced her to lie on the floor. He kissed her, mashed her breasts, and rubbed his penis against her vagina, causing her pain until he ejaculated. The victim, fearing for her life, initially did not report the incident. Her parents discovered the assault on March 15, 1998, after seeing her give money to appellant, prompting her revelation. A medical examination revealed an intact hymen and no vaginal laceration, which the doctor explained could be consistent with mere rubbing.
The defense presented an alibi, claiming a pasyon reading was held at appellant’s house from March 7 to 8, 1998, with around thirty people present, making the alleged rape impossible. Appellant also testified to a long-standing grudge, alleging the complaint was motivated by a family dispute stemming from his past relationship with the victim’s aunt. The defense witnesses, including appellant’s son and brother, corroborated the alibi.

ISSUE

Whether the accused-appellant is guilty beyond reasonable doubt of statutory rape.

RULING

Yes, the Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment crediting the victim’s testimony as straightforward, candid, and credible despite rigorous cross-examination. The testimony of a child victim, absent any ill motive to falsely testify, is accorded great weight. The defense of alibi was properly rejected as inherently weak and insufficient to overcome the positive identification by the victim. The alleged family grudge was deemed specious and uncorroborated, with the Court noting it was improbable for parents to subject their young daughter to a rape trial for mere revenge.
The absence of vaginal laceration or hymenal injury does not negate rape, as the medical expert testified that such injuries may not occur from mere rubbing. Penetration is not required for statutory rape; mere carnal knowledge, defined as the act of a man having sexual intercourse with a woman, is sufficient. The victim’s clear account of penile contact with her vagina satisfied this element. The Court modified the damages, awarding P50,000 as civil indemnity and P50,000 as moral damages, in line with prevailing jurisprudence. The penalty of reclusion perpetua was sustained.