The People of the Philippines, Plaintiff-Appellee, vs. Jose Galvez y Blanca, Accused-Appellant.
FACTS
Five separate Informations were filed against accused-appellant Jose Galvez y Blanca in the Regional Trial Court (RTC) of Malolos, Bulacan for acts committed against his granddaughter, AAA. The charges ranged from acts of lasciviousness in 1999 (when AAA was 10) to rape committed in the years 2000, 2001, 2002, and specifically on June 21, 2002. The prosecution’s evidence primarily consisted of AAA’s testimony. She testified that on June 21, 2002, while she was sleeping, accused-appellant crawled beside her, inserted his penis into her vagina, and threatened her with a knife when she resisted. She later clarified this was not the first incident, stating she was first raped when she was twelve years old (in 2001) and that it happened many times, almost daily from age thirteen to fourteen. She reported the incidents in 2002 to her aunt and pastor, leading to a police report and a medical examination. Dr. Ivan Richard Viray, who examined AAA, concluded she was no longer a virgin and found a shallow healed laceration on her hymen. The defense presented only accused-appellant’s denial of the accusations, without offering an alibi. The RTC convicted Galvez only for the rape on June 21, 2002 (Criminal Case No. 3094-M-2002), acquitting him in the other four cases due to insufficiently detailed testimony and inconsistencies. The RTC sentenced him to Reclusion Perpetua and ordered him to pay damages. The Court of Appeals affirmed the conviction but modified the damages. Accused-appellant appealed to the Supreme Court.
ISSUE
Whether the Court of Appeals erred in affirming accused-appellant’s conviction for the crime of rape.
RULING
The Supreme Court denied the appeal and affirmed the decision of the Court of Appeals with modifications to the awarded damages. The Court held that AAA’s testimony for the June 21, 2002 rape was clear, convincing, and consistent with the medical findings. The Court found her testimony credible, noting that the testimony of a rape victim, especially a minor, is accorded great weight. The defense of bare denial could not prevail over her positive identification. The Court also ruled that the presence of a weapon (a knife) qualified the rape under paragraph 3, Article 335 of the Revised Penal Code, as amended. However, due to the prohibition of the death penalty under Republic Act No. 9346, the proper penalty is Reclusion Perpetua without eligibility for parole. The Court affirmed the award of civil indemnity, moral damages, and exemplary damages but increased the amounts to conform with prevailing jurisprudence, awarding Php75,000.00 as civil indemnity, Php75,000.00 as moral damages, and Php30,000.00 as exemplary damages, all with legal interest from the date of finality of the judgment.
