G.R. No. 184598, June 23, 2009
People of the Philippines, Appellant-Appellee, vs. Julio Manalili, Accused-Appellant.

FACTS

Accused-appellant Julio Manalili was charged with four counts of Rape in relation to Republic Act No. 7610 (the “Special Protection of Children Against Child Abuse, Exploitation and Discrimination Act”). The Amended Informations alleged that on or about February 27, 1997, July 24, 2000, September 21, 2001, and December 28, 2002, in Barangay XXX, XXX City, Julio, the uncle of the victim AAA, willfully, unlawfully, and feloniously had carnal knowledge of AAA through force, threat, and intimidation. AAA was 5, 9, 10, and 11 years old on the respective dates. During trial, AAA testified that Julio sexually assaulted her on these four separate occasions, threatening to kill her and her mother if she reported the incidents. Dr. Cynthia Daniel, who examined AAA, issued a medical report indicating hymenal attenuation, suggestive of sexual abuse. The defense interposed denial and alibi, presenting witnesses to corroborate Julio’s presence elsewhere during the alleged incidents. The Regional Trial Court found Julio guilty on all four counts and initially imposed the death penalty. On automatic review, the Court of Appeals affirmed the conviction but modified the penalty to reclusion perpetua for each count, as the death penalty was statutorily proscribed.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellant Julio Manalili for four counts of rape based on the credibility of the victim’s testimony and the sufficiency of the prosecution’s evidence, despite the defense of denial and alibi and the alleged delay in reporting the incidents.

RULING

The Supreme Court denied the appeal and affirmed the decision of the Court of Appeals with modification. The Court held that the victim’s testimony was credible, straightforward, and consistent. The delay in reporting the incidents, spanning six years from the first rape, was sufficiently explained by the accused’s threats to kill the victim and her mother, which instilled fear. The Court emphasized that in rape cases, the credibility of the victim is paramount, and AAA’s testimony passed the test of credibility. The medical findings corroborated her account. The defenses of denial and alibi were weak and could not prevail over the positive identification by the victim. The Court modified the legal qualification of the crimes from rape under RA 7610 to simple rape, as the informations did not allege AAA’s minority with precision. Accordingly, Julio Manalili was found guilty beyond reasonable doubt of four counts of simple rape and sentenced to suffer the penalty of reclusion perpetua for each count. He was ordered to pay the victim P50,000.00 as civil indemnity, P50,000.00 as moral damages, and P30,000.00 as exemplary damages for each count.