G.R. No. 178406; April 6, 2011
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. RONALDO SALUDO, Accused-Appellant.

FACTS

Accused-appellant Ronaldo Saludo was charged with four counts of rape committed against AAA, a 14-year-old girl, on April 10, April 26, May 19, and June 21, 1995. The Informations alleged that the acts were committed by means of force and intimidation. During arraignment, Saludo pleaded not guilty.
The prosecution presented AAA, her mother CCC, and Dr. Jorge Palomaria. AAA testified that on April 10, 1995, while her mother was at a chapel, Saludo entered their hut, poked a balisong knife at her, and raped her, threatening to kill her and her mother if she reported it. She claimed the rape was repeated on the other dates, each time her mother was away. She only revealed the incidents on July 7, 1995, when her pregnancy became apparent, identifying Saludo as the father. A medical examination on July 16, 1995, confirmed pregnancy and old hymenal lacerations. AAA’s Certificate of Live Birth established her minority.
The defense presented Saludo, neighbors, a barangay kagawad, and the municipal mayor. Saludo denied the accusations, claiming an alibi for April 10, 1995, stating he was at a political meeting and later at a chapel “pabasa.” He suggested the charges were fabricated because AAA had eloped with a certain Jerry Manongsong, and her mother rejected their marriage proposal.
The Regional Trial Court found Saludo guilty of four counts of rape, sentencing him to reclusion perpetua for each count and ordering him to pay ₱50,000.00 civil indemnity per count. The Court of Appeals affirmed the conviction but modified the penalty to a single reclusion perpetua (applying the Indeterminate Sentence Law) and added moral damages of ₱50,000.00 for each count.

ISSUE

Whether the Court of Appeals erred in affirming accused-appellant Ronaldo Saludo’s conviction for four counts of rape.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the Decision of the Court of Appeals with MODIFICATION as to the penalties and damages.
The Court held that AAA’s testimony was credible, straightforward, and consistent. The defense of denial and alibi could not prevail over her positive identification. The medical findings, though not conclusive of rape, were consistent with her testimony of sexual intercourse. The Court found no ill motive for AAA to falsely accuse Saludo.
Regarding the penalties, the Court modified the appellate decision. Since the crimes were committed in 1995, prior to the death penalty’s re-imposition for rape under Republic Act No. 7659, the penalty for each count of rape under Article 335 of the Revised Penal Code, as amended, was reclusion perpetua. The Court imposed the penalty of reclusion perpetua for each of the four counts of rape, to be served successively. The civil indemnity of ₱50,000.00 for each count was affirmed.
Furthermore, the Court increased the award of moral damages to ₱50,000.00 for each count (from the CA’s award) and, applying prevailing jurisprudence, awarded exemplary damages of ₱30,000.00 for each count due to the aggravating circumstance of the victim’s minority. All damages were subject to 6% annual interest from the finality of the judgment until full payment.