GR 172691; (August, 2007) (Digest)
G.R. No. 172691 , August 10, 2007
People of the Philippines, plaintiff-appellee, vs. Antonio Castro y Payawan, accused-appellant.
FACTS
The accused-appellant, Antonio Castro, was charged with the rape of his 14-year-old stepdaughter, AAA. The prosecution alleged that on June 6, 1997, in Mexico, Pampanga, Castro, by means of force and intimidation, had carnal knowledge of AAA against her will. AAA testified that she was sleeping in her mother’s house when Castro pulled her pajamas, covered her mouth, threatened to kill her and her mother if she made noise, and proceeded to rape her. She reported the incident to her grandfather, leading to a barangay report and a medical examination which confirmed she was no longer a virgin and had healed lacerations.
The defense interposed denial. Castro claimed he was sleeping near the door that night and that AAA was still asleep beside her mother when he left for work the next morning. He argued that AAA’s account was doubtful because she did not shout for help despite other relatives living nearby. The Regional Trial Court found Castro guilty of rape and sentenced him to reclusion perpetua, a decision affirmed by the Court of Appeals.
ISSUE
Whether the Court of Appeals erred in affirming the conviction of the accused-appellant for the crime of rape.
RULING
The Supreme Court dismissed the appeal and affirmed the conviction. The Court held that AAA’s categorical testimony, corroborated by medical findings, sufficiently established the elements of rape through force and intimidation. The Court rejected the defense’s argument regarding the victim’s failure to shout for help, emphasizing that the workings of the human mind under emotional stress are unpredictable. Intimidation is subjective and addressed to the mind of the victim; physical resistance is not required when the victim submits out of fear.
The Court found AAA’s testimony credible and consistent. As a minor, she was easily intimidated by the threat to her life and her mother’s, explaining her submission and subsequent silence. The defense of bare denial could not prevail over the positive identification and straightforward narration of the victim. The findings of the trial court, affirmed by the appellate court, on the credibility of witnesses are accorded great weight and respect. Thus, the prosecution proved Castro’s guilt beyond reasonable doubt.