G.R. No. 185203 ; September 17, 2009
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. DOMINGO ARAOJO, Accused-Appellant.

FACTS

Accused-appellant Domingo Araojo was charged with four counts of rape and one count of acts of lasciviousness against his niece, AAA, spanning from 1997 to 2002. The incidents began when AAA was seven years old. The prosecution established that Araojo, who lived with AAA’s family, used threats, a knife, or a bolo to force AAA into submission. The rapes occurred when AAA’s mother, BBB, was away. AAA reported each incident to her mother, who consistently failed to take decisive action, merely promising to talk to Araojo. It was only in 2002, after another rape, that AAA sought help from a relative and a social worker, leading to a medical examination and the filing of charges.
The medical examination revealed old hymenal lacerations consistent with sexual assault. The defense consisted of denial and alibi, claiming AAA’s testimony was fabricated due to a land dispute. The Regional Trial Court convicted Araojo of four counts of rape and one count of acts of lasciviousness, sentencing him to reclusion perpetua for each rape count. The Court of Appeals affirmed the decision, prompting the appeal to the Supreme Court.

ISSUE

The core issue is whether the prosecution proved Araojo’s guilt for the crimes charged beyond reasonable doubt, particularly challenging AAA’s credibility and the sufficiency of her testimony.

RULING

The Supreme Court affirmed the convictions. The Court emphasized that in rape cases, the credibility of the victim is paramount. AAA’s testimony was found to be candid, consistent, and unwavering even under cross-examination. The Court noted that her detailed account of the repeated abuses, including the specific threats and acts, carried the ring of truth. The delay in reporting was sufficiently explained by her young age, continuous fear of the armed appellant, and the ineffective response from her mother, to whom she did report. The failure of a parent to act does not undermine the victim’s credibility.
The medical findings, while not conclusive of rape by themselves, corroborated AAA’s claim of sexual abuse. The defense of denial and alibi, inherently weak, could not prevail over AAA’s positive identification. The Court also upheld the trial court’s assessment of AAA’s age based on her mother’s testimony, as the best evidence rule allows for secondary evidence when original documents are unavailable. Consequently, the Court found all elements of rape and acts of lasciviousness proven beyond reasonable doubt and imposed the penalty of reclusion perpetua for each count of rape.