G.R. No. 195424, June 15, 2015
People of the Philippines, Plaintiff-Appellee, vs. Rudy Nuyok, Accused-Appellant.

FACTS

The victim, AAA, was 13 years old in 2005 and resided in her grandmother BBB’s house in Davao del Sur, where the accused-appellant, her paternal uncle Rudy Nuyok, also lived. AAA testified to four separate incidents of rape committed by Nuyok: on June 25, 2005 (where he punched her stomach, rendering her unconscious, and she awoke to find her clothing disturbed and blood on her panties); in July 2005 (where he crept beside her as she slept, removed her panties, and had carnal knowledge of her despite resistance); in August 2005 (where he punched her stomach and forehead before having carnal knowledge); and in September 2005 (where he threatened her with a scythe before having carnal knowledge). AAA reported the incidents to her grandmother and elder sister, but no action was taken. She finally reported the rapes to her mother in October 2005, leading to a medical examination which revealed a healed hymenal laceration and that her vagina admitted two fingers with ease, indicating previous penetration. The prosecution presented AAA, her mother, and the examining physician. The defense, consisting of Nuyok and his mother BBB, denied the accusations, claiming the house was small and crowded, leaving no opportunity for the crimes, and alleged that AAA’s mother fabricated the charges due to a prior conflict. The Regional Trial Court convicted Nuyok of four counts of rape and sentenced him to reclusion perpetua for each count, plus civil indemnity. The Court of Appeals affirmed the convictions with modifications to the damages.

ISSUE

1. Whether the prosecution proved the guilt of the accused-appellant beyond reasonable doubt.
2. Whether the trial court erred in appreciating the minority of the victim when it was not alleged in the information.

RULING

The Supreme Court denied the appeal and affirmed the convictions.
1. The prosecution proved guilt beyond reasonable doubt. The victim’s testimony was credible, candid, and consistent with medical findings, which indicated previous penetration. The Court upheld the trial court’s assessment of witness credibility. The argument that three informations were defective for stating only the month (July, August, September 2005) and not the exact date was rejected. The date is not a material ingredient of rape; its essence is carnal knowledge through force or intimidation. Precision as to time is not required, and it is sufficient to allege a date as near as possible to the actual commission.
2. The Court found the second issue unmeritorious based on the provided text, which focuses on the sufficiency of the evidence and the validity of the informations regarding the date. The ruling emphasizes that rape can be established by circumstantial evidence and the credible testimony of the victim, even if she was rendered unconscious, and that it can occur in a cramped dwelling despite the probable presence of others, as seclusion is not an element of the crime. The awards of civil indemnity and moral damages for each count of rape were sustained.