G.R. No. 177152 January 6, 2010
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. MANUEL BAGOS, Accused-Appellant.

FACTS

Accused-appellant Manuel Bagos was charged with the rape of AAA, a 10-year-old minor, in an Information dated July 27, 1998. The prosecution’s version, as summarized by the Office of the Solicitor General, states that in May 1998, AAA, along with her siblings and a friend, went to bathe in the Baling-Caguing River. While AAA was alone, Bagos, who was bathing nearby, pulled her leg, lowered her panty to her knees, removed his pants, sat her on his lap in the neck-deep water, and inserted his penis into her vagina despite her protests and boxing of his thighs. He then threatened to shoot her if she reported the incident. AAA’s mother (BBB) later noticed AAA’s unusual behavior and, upon confrontation, AAA revealed the rape. A medical examination on June 18, 1998, by Dr. Maribel Lazo revealed a healed hymenal laceration, indicating loss of virginity more than two weeks prior. The defense, relying solely on Bagos’s testimony, denied the accusation. Bagos claimed he was gathering coconuts near the riverbank and never went near AAA. He speculated that the charge stemmed from a family misunderstanding over a cut tamarind tree and a boundary dispute. The Regional Trial Court (RTC) convicted Bagos of rape and sentenced him to reclusion perpetua, ordering him to pay civil indemnity and moral damages. The Court of Appeals (CA) affirmed the conviction with modification, adding an award of exemplary damages.

ISSUE

Whether the RTC and the CA erred in giving credence to the testimony of the complaining witness and in convicting the accused-appellant despite the alleged failure of the prosecution to prove his guilt beyond reasonable doubt.

RULING

The Supreme Court denied the appeal and affirmed the CA decision with modification. The Court held that the trial court’s assessment of witness credibility is entitled to great weight and respect, finding no reason to deviate from it. AAA’s testimony was found to be credible, straightforward, categorical, and logical, given without ill will. The Court rejected the accused-appellant’s arguments that the testimony was incredible and contrary to human nature, noting that the victim was only ten years old and her candid narration withstood rigorous cross-examination. The medical findings corroborated her account. The failure to shout for help was deemed not contrary to human experience, given the threat and the victim’s age. The defense of denial and alleged motive were found weak and unsubstantiated. The crime committed was statutory rape under Article 266-A(1)(d) of the Revised Penal Code, as the victim was under twelve years of age. The penalty of reclusion perpetua was affirmed. The Court modified the damages awarded: civil indemnity was increased to P75,000.00, moral damages to P75,000.00, and exemplary damages to P30,000.00, all with legal interest of 6% per annum from the date of finality of the judgment until fully paid.