GR 168102; (August, 2008) (Digest)
G.R. No. 168102 ; August 22, 2008
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JAYSON TUAZON Y OLIA, accused-appellant.
FACTS
On March 3, 2001, around 3:30 a.m., AAA was sleeping in her room when she was awakened by appellant Jayson Tuazon, her mother’s common-law husband, kissing her. He mounted her, touched her breasts, and bit her nipples. He then poked a fan knife at her, threatening her not to tell anyone. Later, while she was cooking downstairs under his guard, he again threatened her with the knife, touched her breasts and private part, and forced her to lie down. He removed her clothing, licked her body, and then had sexual intercourse with her. AAA felt his penis penetrate her vagina. Afterward, he wiped her with a handkerchief. AAA’s mother and sister returned around 7 a.m., noticed her swollen eyes and tears, and were informed of the rape. They immediately reported the incident to the police, and AAA underwent a medical examination.
ISSUE
Whether the prosecution proved the guilt of the accused for the crime of rape beyond reasonable doubt.
RULING
Yes. The Supreme Court affirmed the conviction. The Court emphasized that in rape cases, the credibility of the victim’s testimony is paramount. AAA’s detailed, candid, and consistent narration of the harrowing incident, from the initial assault to the sexual intercourse, was found credible and sufficient to establish the elements of rape through force and intimidation. The use of a fan knife and appellant’s moral ascendancy as a stepfather-figure constituted the intimidation that subdued AAA’s will. The medical findings, though not showing fresh lacerations, were consistent with AAA’s testimony as she was no longer a virgin, and the absence of spermatozoa did not negate rape, as completion of the crime does not require emission. The defense of denial and alibi was weak and uncorroborated, failing to overcome the positive identification and credible testimony of the victim. The award of damages was modified, with civil indemnity and moral damages at P50,000 each, and exemplary damages at P25,000, in line with prevailing jurisprudence.