G.R. No. 172874 December 17, 2008
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MARIO CASTRO, accused-appellant.

FACTS

Accused-appellant Mario Castro was charged with the rape of his 14-year-old sister-in-law, AAA, on or about November 11, 1999, in Taguig, Metro Manila. The prosecution’s version, based on AAA’s testimony, states that on the evening of November 11, 1999, accused-appellant fetched AAA by falsely claiming her elder sister had collapsed. Instead of taking her to a clinic, he brought her to a dark alley near an abandoned factory. There, he strangled and threatened to kill her if she screamed. He then undressed her, kissed her body, and forced his penis into her vagina, satisfying his lust. Afterward, he brought her to a terminal but changed his mind and took her back to the same area where he raped her a second time. AAA reported the incident to her relatives, who brought her for a medical examination and to file a complaint. The defense presented Margarita Salangsang, who testified that accused-appellant was at her birthday celebration from 9:30 PM to midnight on November 11, 1999, and did not leave. The Regional Trial Court convicted accused-appellant of rape and sentenced him to reclusion perpetua, which the Court of Appeals affirmed.

ISSUE

1. Whether the trial court erred in giving full weight and credence to the testimony of the private complainant.
2. Whether the trial court erred in convicting accused-appellant of rape instead of acts of lasciviousness.

RULING

The Supreme Court affirmed the decision of the Court of Appeals, finding accused-appellant guilty beyond reasonable doubt of simple rape. The Court held that the trial court’s findings on the credibility of witnesses are entitled to great respect, as it had the opportunity to observe their demeanor. The Court found AAA’s testimony to be consistent, spontaneous, and straightforward, detailing how accused-appellant used force and intimidation to have carnal knowledge of her. The Court rejected accused-appellant’s arguments that her testimony was improbable, noting that she clearly testified she was forced to lie down and that accused-appellant inserted his penis into her vagina. The Court also found the defense of alibi weak, as it was not physically impossible for accused-appellant to be at the crime scene. The crime was qualified as simple rape under Article 266-A of the Revised Penal Code, as amended by R.A. 8353, due to AAA’s minority (14 years old) and the use of force and intimidation. The penalty of reclusion perpetua was upheld. Accused-appellant was ordered to pay AAA P50,000.00 as civil indemnity and P50,000.00 as moral damages.