GR 196435; (January, 2014) (Digest)
G.R. No. 196435; January 29, 2014
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs. JOEL CRISOSTOMO y MALLIAR, Accused-Appellant.
FACTS
The accused-appellant, Joel Crisostomo, was charged with two counts of rape by sexual assault and one count of statutory rape against “AAA,” a six-year-old child. The prosecution alleged that on April 8, 1999, Crisostomo, who worked at a vulcanizing shop owned by AAA’s father, lured AAA into his house. There, he burned her genital and anal orifices with a lighted cigarette and then had carnal knowledge of her. The child’s testimony was corroborated by the medico-legal report of Dr. Emmanuel Reyes, which confirmed third-degree burns in the perianal region and loss of virginity consistent with recent sexual intercourse.
The defense presented an alibi, claiming Crisostomo was asleep at the time of the incident due to his night shift work. A witness, Mary Pabuayan, also testified that AAA’s burns were accidentally caused by a playmate named Joel “Liit,” the son of the accused, while burning worms near a santol tree on a Good Friday in 1999. The Regional Trial Court convicted Crisostomo on all counts, a decision affirmed with modification by the Court of Appeals.
ISSUE
Whether the Court of Appeals erred in affirming the conviction of the accused-appellant for the crimes charged.
RULING
The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of witness credibility, which is generally accorded great weight and respect. It found the testimony of the child-victim, delivered in a candid and straightforward manner, to be credible and consistent. The defense of alibi was inherently weak and could not prevail over the positive identification by the victim. The alternative explanation for the burns offered by the defense witness was rejected as unreliable; the Court noted the witness’s claim that the incident occurred on a “Good Friday” was dubious since April 8, 1999, was a Thursday, and the story of accidentally burning worms did not plausibly account for the specific, severe injuries to the victim’s intimate parts.
On the penalties, the Court modified the award of damages in line with prevailing jurisprudence. For each count of rape by sexual assault, the penalty of reclusion temporal in its medium period was affirmed, with the indemnity, moral damages, and exemplary damages set at P50,000.00 each. For statutory rape, the penalty of reclusion perpetua was affirmed, with corresponding damages of P75,000.00 as civil indemnity, P75,000.00 as moral damages, and P30,000.00 as exemplary damages. All monetary awards were subject to 6% annual interest from the finality of judgment until fully paid.