G.R. No. 168103 ; August 3, 2010
PEOPLE OF THE PHILIPPINES, Appellee, vs. ALEJANDRO RELLOTA Y TADEO, Appellant.

FACTS

The appellant, Alejandro Rellota, was convicted of two counts of consummated rape and one count of attempted rape against AAA, his wife’s niece who was twelve years old at the time. The incidents occurred between September 1993 and January 1994 in Antipolo City while AAA was living in the appellant’s household. AAA testified that the appellant sexually assaulted her on multiple occasions, using force, intimidation, and threats, including placing a bolo beside him and threatening to harm her siblings and stop her schooling. Specific instances detailed included two assaults in December 1993 and an attempted assault on January 31, 1994, where AAA resisted by kicking and scratching the appellant. The complaints were consolidated for trial.
The Regional Trial Court found the appellant guilty of three counts of rape and sentenced him to reclusion perpetua for each count. The Court of Appeals affirmed the convictions but reclassified one charge from consummated rape to attempted rape for the January 31 incident, as the prosecution only proved that the appellant kissed and touched the victim but did not establish sexual intercourse for that specific event. The appellant appealed, arguing the credibility of the young victim.

ISSUE

The core issue is whether the testimony of the minor victim, AAA, is credible and sufficient to sustain the appellant’s conviction for the crimes charged.

RULING

The Supreme Court affirmed the decision of the Court of Appeals with modifications to the awarded damages. The Court upheld the conviction, emphasizing that the testimony of a child-victim of rape, given in a categorical, straightforward, and convincing manner, is accorded full weight and credit. The Court found AAA’s testimony to be consistent and credible, noting that youth and immaturity are generally badges of truth. Her detailed account of the assaults, including her resistance, was deemed credible and sufficient to prove the appellant’s guilt beyond reasonable doubt.
The Court rejected the appellant’s denial and implausible motive of a loan dispute as a defense, holding that such denial cannot prevail over the positive and credible identification by the victim. Regarding the January 31 incident, the Court agreed with the CA’s reclassification to attempted rape, as the evidence only proved lascivious conduct short of carnal knowledge. The legal logic is that for consummated rape under the Revised Penal Code, proof of the insertion of the male organ into the female organ is essential; its absence for that specific date warrants the lesser conviction. The Court modified the civil indemnity and awarded moral and exemplary damages in line with prevailing jurisprudence.