G.R. No. 190863 , November 19, 2014
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. RAUL SATO, Accused-Appellant.

FACTS

The accused-appellant, Raul Sato, was charged with the statutory rape of “AAA,” a nine-year-old girl, on September 10, 2004, in Cebu. The Information alleged that he had carnal knowledge of the victim by means of force, violence, and intimidation. During trial, the prosecution presented the testimony of “AAA,” who recounted that appellant, their neighbor, invited her and her six-year-old cousin “BBB” to an abandoned nipa hut. He carried “AAA” inside, ordered both children to undress, played with “AAA’s” private parts, inserted his penis into her vagina while making coital movements (causing her pain), gave her ₱5.00 afterward, and threatened to kill her and her father if she reported the incident. Prosecution witness Efren Alcover testified that while gathering banana trunks near the hut, he saw appellant, “AAA,” and “BBB” naked inside; he witnessed appellant on top of “AAA” making push-and-pull movements. A medical examination conducted on “AAA” the following day revealed hyperemia (increased redness) of her hymen. The defense consisted of denial and alibi, with appellant claiming he was fishing, cooking, and sleeping at the time of the incident, and alleging that the case was motivated by previous disputes with “AAA’s” family. The Regional Trial Court found appellant guilty of statutory rape and sentenced him to reclusion perpetua, ordering him to pay civil indemnity, moral damages, and exemplary damages. The Court of Appeals affirmed the conviction but modified the damages, increasing moral damages and deleting exemplary damages for lack of basis.

ISSUE

Whether the Court of Appeals erred in affirming appellant’s conviction for statutory rape despite the alleged improbabilities in the victim’s testimony and the defenses of denial and alibi.

RULING

The Supreme Court denied the appeal and affirmed the conviction with modifications to the awards of damages. The Court held that the alleged improbabilities raised by appellant (such as committing rape in the presence of another child, not presenting “BBB” as a witness, not also molesting “BBB,” the medical findings showing only hyperemia and no laceration, and the witness Alcover’s failure to intervene) were inconsequential and did not affect the essential elements of the crime. The testimony of the child-victim “AAA” was given full weight and credit, being candid, spontaneous, and consistent. Her young age was considered a badge of truth, and her account was corroborated by the eyewitness testimony of Alcover. The defenses of denial and alibi were inherently weak and could not prevail over the positive identification and credible testimonies of the prosecution witnesses. Appellant failed to prove the physical impossibility of being at the crime scene. The Court modified the damages in line with prevailing jurisprudence: civil indemnity was increased to ₱75,000.00; moral damages were set at ₱75,000.00; exemplary damages of ₱30,000.00 were awarded; and all monetary awards were to earn interest at 6% per annum from the finality of judgment until fully paid. The penalty of reclusion perpetua, without eligibility for parole, was affirmed.