GR 198059; (April, 2014) (Digest)
G.R. No. 198059 , April 7, 2014
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. ANTONIO LUJECO y MACANOQUIT alias “TONYO”, Accused-Appellant.
FACTS
Accused-appellant Antonio Lujeco y Macanoquit was charged with the rape of “AAA,” a seven-year-old minor, committed on June 29, 2002. He pleaded not guilty. The Regional Trial Court found him guilty of statutory rape, a decision affirmed by the Court of Appeals. The prosecution established that on the morning of June 29, 2002, “AAA” was playing near her house when appellant grabbed her, dragged her to a nearby house, forcibly undressed her, poked a knife at her, and had carnal knowledge of her. Medical examination revealed fresh hymenal lacerations and contusion-hematoma on her labia majora. Appellant claimed alibi, asserting he was at the public market at the time, and argued that the victim’s testimony was coached by her mother, who was embracing her while she testified.
ISSUE
The primary issue is whether the trial and appellate courts erred in convicting appellant based on the credibility of the victim’s testimony and in rejecting his defense of alibi.
RULING
The Supreme Court dismissed the appeal and affirmed the conviction with modifications. The Court held that the victim’s testimony was credible, categorical, and straightforward, and was corroborated by medical findings. The presence of her mother as a “support person” during testimony, to which the defense did not object, did not constitute coaching but was a mere reminder to remember details. The defense of alibi failed as appellant did not prove it was physically impossible for him to be at the crime scene. The elements of statutory rape under Article 266-A of the Revised Penal Code were satisfied: carnal knowledge with a woman below twelve years of age. The penalty of reclusion perpetua was affirmed, with the declaration that appellant is not eligible for parole. The awards of civil indemnity and moral damages were each reduced to ₱50,000.00; the award of actual damages was deleted for lack of basis; and exemplary damages of ₱30,000.00 were granted. All damages shall earn legal interest at 6% per annum from the finality of judgment until fully paid.