G.R. No. 194946 ; September 3, 2014
People of the Philippines, Plaintiff-Appellee, vs. Eco Yaba y Basa a.k.a. “Plok,” Accused-Appellant.

FACTS

The accused-appellant, Eco Yaba y Basa, was charged with the rape of AAA, a 15-year-old minor, on July 8, 2005, in Camarines Sur. The prosecution’s version, as narrated by AAA, stated that she was on her way home, accompanied by the accused-appellant with her grandmother’s permission. After she asked him to return home and proceeded alone, the accused-appellant surprised her, grabbed her hair, punched and kicked her, threatened her with a stone and with harm from an NPA cousin, forcibly undressed her, and had carnal knowledge against her will. Afterward, he accompanied her to her home. Her cousin BBB noticed her distressed state, and AAA later revealed the rape. A medical examination the next day revealed contusions, abrasions, and a perineal laceration. The defense claimed AAA and the accused-appellant were lovers, that the injuries were from a fall during heavy rain, and that AAA was menstruating. Defense witnesses testified they were seen together hand-in-hand.

ISSUE

Whether the accused-appellant is guilty beyond reasonable doubt of the crime of rape.

RULING

The Supreme Court affirmed the conviction. The trial court’s findings on the credibility of AAA’s straightforward and categorical testimony were accorded great weight and respect. The Court rejected the “sweetheart theory” for lack of compelling evidence and held that even if true, it does not negate rape. The medical findings corroborated AAA’s account, and the doctor testified the perineal laceration was consistent with penile penetration, not a fall. The Court sustained the penalties imposed by the lower courts: Reclusion Perpetua and awards of civil indemnity, moral damages, and exemplary damages, with the modification that all damages shall earn interest at 6% per annum from finality of judgment until fully paid.