GR 185389; (July, 2009) (Digest)
G.R. No. 185389 ; July 7, 2009
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. BENJIE RESURRECCION, Accused-Appellant.
FACTS
The accused-appellant, Benjie Resurreccion, was charged with the rape of AAA, an 11-year-old girl, on December 5, 2000. Benjie was a domestic helper in the victim’s household. The prosecution alleged that in the late afternoon, Benjie grabbed AAA, covered her mouth, forcibly dragged her to her room, and had sexual intercourse with her against her will. AAA reported the incident to her aunt the following day, leading to a police report and a medical examination. The medical examination, conducted two days post-incident, revealed no hymenal laceration and an absence of spermatozoa. The defense presented denial, claiming the accusation was fabricated due to familial disputes and suspicion that Benjie had stolen money from AAA’s parents.
The Regional Trial Court convicted Benjie of simple rape and sentenced him to reclusion perpetua, ordering him to pay ₱50,000.00 in damages. The Court of Appeals affirmed the conviction but modified the damages to ₱50,000.00 as civil indemnity and another ₱50,000.00 as moral damages. Benjie appealed to the Supreme Court, arguing the victim’s testimony was improbable and the medical findings negated the commission of rape.
ISSUE
Whether the Court of Appeals erred in affirming Benjie Resurreccion’s conviction for simple rape despite his claims regarding the improbability of the victim’s testimony and the exculpatory nature of the medical findings.
RULING
The Supreme Court denied the appeal and affirmed the decision of the Court of Appeals. The Court emphasized that in rape cases, the credibility of the victim’s testimony is paramount. The victim’s clear, consistent, and candid account of the forcible sexual assault was deemed credible and sufficient to establish guilt beyond reasonable doubt. The Court found no inherent improbability in her narration; the act of covering the victim’s mouth and pinning her down was a plausible method of subduing an 11-year-old child.
The Court also ruled that the absence of physical injuries or spermatozoa does not disprove rape. The medical expert explained that an elastic hymen may not lacerate, and the absence of sperm could be due to the two-day delay before examination or the victim washing herself. The defense of denial and imputation of ill motive were weak and unsupported by evidence, especially against the positive and credible identification by the minor victim. The penalty of reclusion perpetua was proper, and the awards of civil indemnity and moral damages were in accordance with prevailing jurisprudence.