G.R. No. 181544 ; April 11, 2012
People of the Philippines, Plaintiff-Appellee, vs. Julius Taguilid y Bacolod, Accused-Appellant.

FACTS

The accused-appellant, Julius Taguilid, was convicted of rape by the Regional Trial Court. The prosecution evidence established that on May 29, 2002, Taguilid, a cousin of the victim’s mother living with the family, entered the 12-year-old victim’s (AAA) room. He pushed her down, inserted his finger into her vagina, and then had sexual intercourse with her. He subsequently turned her over and penetrated her anus. AAA cried and tried to push him away but desisted when he threatened to kill her. Her father (BBB) later entered the room and found Taguilid zipping his pants, with AAA on the bed crying and her clothing disheveled. A medico-legal examination confirmed AAA was in a non-virgin state with deep, healed hymenal lacerations.
Taguilid denied the rape. Initially, he claimed his presence in the room was misunderstood, stating he was merely pulling up his shorts after an altercation with AAA. On appeal, however, he shifted his defense, admitting to sexual intercourse but asserting it was consensual.

ISSUE

Whether the Court of Appeals correctly affirmed the conviction of Julius Taguilid for the crime of rape.

RULING

The Supreme Court affirmed the conviction. The Court found the victim’s testimony to be credible, straightforward, and consistent. Her detailed account of the sexual assault, including the use of force, intimidation, and the threat to kill her, was corroborated by her father’s timely discovery of the scene and the medico-legal findings. The healed lacerations were consistent with a history of sexual abuse, which aligned with AAA’s claim of multiple prior assaults.
The Court rejected Taguilid’s defenses as unreliable and indicative of guilt. His initial denial and subsequent shift to a theory of consensual sex constituted an admission of the sexual act while failing to refute the element of force or intimidation. Consent is immaterial in statutory rape, but the Court further noted that the victim, being a minor of tender age, could not have given meaningful consent. Moreover, Taguilid’s moral ascendancy as a relative living in the household facilitated the abuse. The inconsistent and vacillating nature of his defenses, contrasted with the prosecution’s strong evidence, solidified his guilt beyond reasonable doubt. The penalty of reclusion perpetua and awarded damages were thus upheld.