GR 140203; (January, 2002) (Digest)
G.R. No. 140203; January 31, 2002
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EDDIE S. FERNANDEZ, accused-appellant.
FACTS
The case involves the rape of nine-year-old Jennifer Nieva Frias by her uncle, accused-appellant Eddie S. Fernandez, sometime in November 1997 in Tanay, Rizal. At the time, Jennifer was living in her aunt’s house, which Fernandez frequented. On the day of the incident, after the aunt left to wash clothes and Fernandez sent Jennifer’s siblings away, he raped the child. The crime was later discovered when the aunt witnessed Jennifer and her sister playing with Fernandez’s penis. Upon questioning, Jennifer disclosed the rape.
A complaint was lodged with the police. A medico-legal examination confirmed Jennifer was in a non-virgin state, showing a deep healed hymenal laceration, which corroborated her account. An Information for rape was filed. The Regional Trial Court convicted Fernandez of rape, sentencing him to reclusion perpetua and ordering him to pay civil indemnity. Fernandez appealed, questioning the credibility of the prosecution’s witnesses and relying on denial and alibi.
ISSUE
Whether the prosecution proved the guilt of accused-appellant Eddie S. Fernandez beyond reasonable doubt for the crime of rape.
RULING
The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of witness credibility, emphasizing that such findings are entitled to great respect as the trial judge observes the witnesses’ demeanor firsthand. The testimony of the young victim, Jennifer, was found to be clear, candid, and consistent, bearing the hallmarks of truth and sincerity typical of a child of tender years. Her detailed account of the sexual assault, including her resistance and the pain she felt, was deemed credible.
The Court rejected the defense of denial and alibi, which are inherently weak and cannot prevail over the positive and credible identification by the victim. The medical findings provided physical corroboration. Furthermore, the Court found no ill motive for Jennifer or her family to fabricate such a grave charge. The crime was qualified as statutory rape due to the victim’s age, punishable by reclusion perpetua. The Court modified the damages, awarding moral damages in the amount of Fifty Thousand Pesos (P50,000.00) in addition to civil indemnity of the same amount, recognizing that moral suffering is inherent in rape cases and requires no further proof.