G.R. No. 170636; April 27, 2007
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. SONNY MAYAO, Accused-Appellant.

FACTS

Accused-appellant Sonny Mayao was charged with three counts of rape against different victims: his stepdaughter AAA (Criminal Case No. T-2044), his niece BBB (Criminal Case No. T-2045), and his stepdaughter CCC (Criminal Case No. T-2046). The incidents allegedly occurred in Lagonoy, Camarines Sur, between 1992 and 1996. AAA testified that in 1996, while her family slept, Mayao undressed and sexually assaulted her. BBB recounted that in 1992, while staying at Mayao’s house, he fondled and raped her at midnight. CCC stated that on December 20, 1995, Mayao assaulted her when they were alone. Medical examinations in 1999 revealed old hymenal lacerations consistent with sexual intercourse for all three complainants.
The defense was denial and alibi. Mayao claimed AAA did not live with him in 1996, BBB was in Manila or at another relative’s house in 1992, and CCC was working elsewhere in 1995. He alleged the complaints were motivated by a desire for financial gain, inspired by the Baby Echegaray case. The Regional Trial Court convicted Mayao on all counts, a decision affirmed by the Court of Appeals. He appealed to the Supreme Court, arguing the prosecution failed to prove his guilt beyond reasonable doubt.

ISSUE

Whether the prosecution successfully proved the guilt of accused-appellant Sonny Mayao for three counts of rape beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the convictions. The Court found the testimonies of the three private complainants to be credible, consistent, and convincing. The victims provided clear, categorical, and coherent accounts of the assaults. Their testimonies were corroborated by medical findings of old hymenal lacerations, which, while not conclusive by themselves, lent credence to their claims of prior sexual abuse. The Court dismissed the defense of alibi as weak and unsubstantiated, noting it cannot prevail over the positive identification by the victims. The alleged delay in reporting, particularly by BBB and CCC, was sufficiently explained by their youth, fear, and the accused’s moral ascendancy as a stepfather and uncle. The Court found no ill motive for the victims to falsely accuse Mayao, rejecting the claim of financial inspiration as speculative. For the rape of BBB, who was under twelve years old at the time, carnal knowledge alone was sufficient to constitute rape under Article 335 of the Revised Penal Code, as force or intimidation need not be proven. The Court modified the penalty for the rape of AAA and CCC to reclusion perpetua only, as the informations did not allege the victims’ precise ages below eighteen to qualify for the death penalty under Republic Act No. 7659. The awards of civil indemnity, moral damages, and exemplary damages were sustained.