G.R. No. 180923 ; April 30, 2009
People of the Philippines, Appellee, vs. Salomon Dioneda y Dela Cruz a.k.a. Simon Dioneda Dela Cruz, Appellant.

FACTS

On August 27, 2000, in Quezon City, appellant Salomon Dioneda y Dela Cruz, then 17 years old, was charged with the rape of AAA, a six-year-old minor, by means of force and intimidation. The prosecution established that AAA went to a neighbor’s house to play. Appellant, a helper in that house, prevented her from leaving, forced her to the second floor, made her lie down, removed her panties, and had carnal knowledge with her. AAA felt pain, and appellant wiped her vagina and warned her not to tell anyone. AAA ran home crying, reported the incident to her parents, and showed her bloodstained panties. Her parents confronted appellant and reported the matter to the authorities. A medico-legal examination confirmed fresh lacerations and bruises consistent with sexual abuse and penetration. Appellant denied the accusation, claiming he was merely watching TV and was later confronted by AAA’s father. The Regional Trial Court found appellant guilty of rape under Article 266-A of the Revised Penal Code, as amended. Considering his minority (17 years old at the time of the crime) as a privileged mitigating circumstance, the penalty was reduced by one degree to reclusion perpetua. The court also awarded civil indemnity, moral damages, and exemplary damages. The Court of Appeals affirmed the conviction but modified the exemplary damages award.

ISSUE

Whether the trial court erred in giving full weight and credence to the testimonies of the prosecution witnesses, particularly assailing the credibility of the child victim AAA due to alleged inconsistencies in her testimony regarding the floor of the house where she met appellant before the rape.

RULING

The Supreme Court DISMISSED the appeal and AFFIRMED the Decision of the Court of Appeals. The Court held that the alleged inconsistency in AAA’s testimony—whether she met appellant on the ground floor or second floor—was trivial and immaterial. As a child of tender age, AAA could not be expected to give a perfect recollection of such minor details. Trivial inconsistencies do not impair credibility and can even be badges of truth, manifesting spontaneity and absence of a rehearsed testimony. Such minor inaccuracies are irrelevant to the elements of the crime and do not create reasonable doubt. Appellant’s guilt was established beyond reasonable doubt by the credible testimony of the victim and corroborating medical evidence. The award of damages was sustained, with the modification on exemplary damages by the Court of Appeals affirmed.