GR 154917; (May, 2004) (Digest)
G.R. No. 154917; May 18, 2004
PEOPLE OF THE PHILIPPINES, appellee, vs. RODANIEL VILLAFUERTE, appellant.
FACTS
The prosecution established that on February 18, 1998, in San Fernando, Pampanga, appellant Rodaniel Villafuerte, then fifteen, lured six-year-old Christine Joy Santos to an old bathroom after playing with her and her cousins. Inside, he undressed her and himself, and inserted his penis into her genitalia. Christine felt pain, kicked appellant, and immediately reported the incident to her mother, leading to a police blotter and a medical examination. The medico-legal report noted no lacerations but found her labia coapted. Appellant was charged with rape under Article 266-A of the Revised Penal Code.
At trial, appellant denied the accusation, presenting an alibi through his niece, Rosemarie Villafuerte, who testified they were all playing “Lutu-lutuan” and that appellant merely fixed their playhouse before leaving. The defense highlighted alleged inconsistencies between Christine’s sworn statement and her court testimony regarding the details of the penetration.
ISSUE
Whether the trial court erred in convicting appellant of statutory rape based on the credibility of the child victim’s testimony despite alleged inconsistencies and the absence of physical injuries.
RULING
The Supreme Court affirmed the conviction. The Court held that the alleged inconsistencies in the child victim’s testimony did not undermine her credibility but instead bolstered its spontaneity and candor. The sworn statement was prepared by another and merely thumbmarked by Christine when she was six, while her court testimony at age nine was more coherent. The Court emphasized that testimonies of young rape victims, characterized by straightforwardness and simplicity, deserve full credence. It is highly improbable for a naive six-year-old to fabricate a humiliating story of defloration, undergo medical examination, and endure a public trial unless motivated by a genuine desire for justice.
The absence of lacerations or physical injuries does not negate rape, as the medico-legal finding of coapted labia was consistent with the attempted penetration described by the victim. The defense of alibi was weak and uncorroborated. Given the victim’s age, the crime constituted statutory rape where force, intimidation, or consent are immaterial. The penalty of reclusion perpetua and awards of P50,000 civil indemnity and P50,000 moral damages were affirmed.