GR 173307; (July, 2013) (Digest)
G.R. No. 173307 ; July 17, 2013
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. VICTORINO REYES, Accused-Appellant.
FACTS
On December 26, 1996, the 13-year-old victim, AAA, and her younger sister BBB were watching television at the house of their neighbor, accused-appellant Victorino Reyes. When the girls attempted to leave at around 9:00 p.m., Reyes forcibly pulled AAA into an attached store. He threatened to kill her if she shouted, kissed her, mashed her breasts, and pulled down her pants and panties. Despite AAA’s physical resistance, Reyes succeeded in parting her legs and thrust his penis into her vagina, achieving a slight penetration. Afterward, he threatened both sisters to ensure their silence.
Upon returning home, AAA’s mother, CCC, grew suspicious and discovered semen on AAA’s soiled panties. AAA then confessed to the rape. A medical examination conducted the following day revealed contusions on AAA’s labia majora but no hymenal lacerations. Reyes was charged with rape under Article 335 of the Revised Penal Code. The Regional Trial Court convicted him of rape and sentenced him to reclusion perpetua, a decision affirmed by the Court of Appeals.
ISSUE
Whether the accused-appellant is guilty of the crime of rape despite the medical finding of an intact hymen and his claim of only slight penetration.
RULING
The Supreme Court affirmed the conviction. The Court held that the crime of rape is consummated by the slightest penetration of the female genitalia. Full penetration or the rupture of the hymen is not required. The medical finding of contusions on the labia majora corroborated AAA’s testimony that penile penetration occurred. The Court emphasized that the credibility of the victim’s clear, consistent, and convincing testimony, as affirmed by both lower courts, prevails over the accused’s denial and his implausible claim that the charge was fabricated due to a debt.
The defense’s argument that the intact hymen disproved carnal knowledge was legally erroneous. The Court reiterated that in rape cases, the testimony of the victim, if credible, is sufficient to sustain a conviction. The accused’s moral ascendancy and the threats he employed rendered the victim’s resistance futile. The penalty of reclusion perpetua was upheld. The Court modified the damages, awarding civil indemnity, moral damages, and exemplary damages, all with legal interest.