G.R. No. 192253; September 18, 2013
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. CARLITO ESPENILLA, Accused-Appellant.

FACTS

The case is an appeal from the Court of Appeals Decision affirming the Regional Trial Court’s conviction of Carlito Espenilla for Simple Rape under Article 335 of the Revised Penal Code (prior to its amendment by R.A. No. 8353). The Information dated March 30, 1999, alleged that on or about October 20, 1995, in Masbate, the accused, by means of violence and intimidation, had carnal knowledge with AAA, a 13-year-old girl, against her will.
The prosecution evidence, primarily from AAA’s testimony, established that at around 7:00 a.m. on October 20, 1995, while AAA was at home with her younger siblings, the accused-appellant, her stepmother’s brother, arrived. He asked for a tobacco leaf and newspaper. When AAA went inside a room to get them, he followed, closed the door, and while armed with a bolo, undressed her, threatened to kill her if she told anyone, and then forcibly had sexual intercourse with her. She cried in pain but did not resist due to his strength and the bolo. He made thrusting motions for about five minutes. Later that same day, in the late afternoon or early evening, he returned and raped her a second time, repeating his threats. Out of fear, AAA kept silent but eventually ran away and disclosed the incident to a Barangay Captain, leading to a police investigation and a medico-legal examination on January 7, 1999. The medical findings showed “Old healed hymenal laceration at 3, 6, 9 o’clock position. Admits two fingers with resistance.”
The defense presented AAA’s father, BBB, and the accused-appellant. BBB executed an Affidavit of Recantation, claiming he forced his daughter to fabricate the rape story due to a misunderstanding over property and a debt, and that the real rapist was someone killed by the NPA. On the stand, he gave conflicting statements, initially affirming the rape complaint but later claiming it was fabricated. The accused-appellant merely denied the accusation, alleging it was fabricated because of a Php1,000.00 debt he owed BBB, and did not offer an alibi.
The RTC found AAA’s testimony credible and convicted the appellant, sentencing him to Reclusion Perpetua and ordering him to pay civil indemnity and moral damages. The CA affirmed the RTC decision.

ISSUE

Whether the Court of Appeals erred in affirming the trial court’s conviction, specifically in giving full credence to the testimony of the private complainant and in finding the accused-appellant guilty beyond reasonable doubt despite the alleged failure of the prosecution to prove his guilt.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the conviction. The Court held that the prosecution successfully proved the guilt of the accused-appellant beyond reasonable doubt.
1. Credibility of AAA’s Testimony: The Court found AAA’s detailed, candid, and consistent narration of the rape credible. Her testimony clearly established all the elements of rape under the then-applicable Article 335 of the Revised Penal Code: (a) carnal knowledge occurred; (b) it was done through force and intimidation (the use of a bolo and threats to kill); and (c) it was against her will. The medical certificate, showing old healed hymenal lacerations, corroborated her claim of sexual intercourse. The delay in reporting was sufficiently explained by the accused’s threats, which instilled fear in the young victim.
2. Failure of the Defense: The defense of denial and the alleged motive of debt collection were weak and self-serving, especially when weighed against the positive and credible identification by the victim. The Affidavit of Recantation executed by BBB was unreliable. The Court emphasized that recantations are viewed with extreme caution and are often considered inferior to testimonies given in open court. BBB’s vacillating statements during trial further undermined his credibility. The defense failed to present any compelling evidence to overturn the consistent findings of the trial court and the Court of Appeals regarding the victim’s credibility.
3. Damages: The award of civil indemnity and moral damages was sustained. The Court noted that at the time of the offense, the penalty for simple rape was reclusion perpetua. The awards of ₱50,000.00 as civil indemnity and ₱50,000.00 as moral damages were in accordance with prevailing jurisprudence.
The Supreme Court found no reason to deviate from the factual findings of the lower courts, which had the direct opportunity to observe the witnesses’ demeanor. The appeal was without merit.