GR 194612; (January, 2014) (Digest)
G.R. No. 194612; January 27, 2014
People of the Philippines, Plaintiff-Appellee, vs. Floro Manigo y Macalua, Accused-Appellant.
FACTS
The accused-appellant, Floro Manigo y Macalua, was charged with the rape of “AAA,” a 13-year-old minor. The prosecution alleged that on April 16, 2004, in Tagum City, appellant, a tricycle driver, transported AAA and her classmate. After dropping off the classmate, appellant diverted the route, brought AAA to a secluded banana plantation, and at knifepoint, forced her to undress and had carnal knowledge of her against her will. AAA reported the incident the following day, leading to a medical examination which confirmed recent sexual abuse. She later positively identified appellant in a police line-up.
The defense interposed denial and alibi. Appellant claimed he was not a tricycle driver but a money lender, was at home during the incident, and only saw AAA for the first time during the police line-up. The Regional Trial Court found appellant guilty beyond reasonable doubt of rape under Article 266-A of the Revised Penal Code, as amended, and sentenced him to reclusion perpetua. The Court of Appeals affirmed the conviction but modified the awarded damages.
ISSUE
The pivotal issue is whether the testimony of the victim, AAA, is credible and sufficient to sustain a conviction for rape beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction. The Court emphasized that in rape cases, the credibility of the victim is paramount. AAA’s testimony was found to be straightforward, convincing, and consistent with human nature. She provided a detailed and unshaken account of the assault, including her initial resistance, the use of a knife, and her subsequent identification of appellant, noting a distinctive tattoo on his arm. The medical certificate corroborated her claim of recent sexual violation. The Court held that such a credible and positive testimony prevails over the weak defenses of denial and alibi, which are inherently unreliable unless supported by clear and convincing evidence. The defense failed to provide any plausible motive for AAA to falsely accuse appellant. The award of damages was also sustained, with civil indemnity, moral damages, and exemplary damages being proper given the crime’s gravity and the victim’s minority. The penalty of reclusion perpetua was affirmed as the prescribed penalty for statutory rape.