G.R. No. 200077 , September 17, 2014
People of the Philippines, Plaintiff-Appellee, vs. Adel Ramos y Abellana, Accused-appellant.

FACTS

Accused-appellant Adel Ramos y Abellana was charged with four counts of Rape against the minor “AAA” in similarly worded Informations. The first incident was specifically dated July 17, 2007; the second on January 29, 2008; and the third and fourth were stated to have occurred sometime between July 17, 2007, and January 29, 2008. Upon arraignment, Ramos pleaded not guilty. The cases were consolidated and jointly tried. The prosecution presented AAA, her mother BBB, a medico-legal officer, and AAA’s friend. AAA testified that the first rape occurred at 3:00 a.m. on July 17, 2007, inside the comfort room of Ramos’s house, where he threatened her with a gun. The second rape happened when she was on an errand to deliver food to Ramos’s house. The third occurred when she returned items to Ramos’s house. The fourth and final rape took place at around 3:00 a.m. on January 29, 2008, in an outside comfort room. AAA revealed the rapes to her friend Roselyn three days after the last incident, and subsequently to her mother, leading to a police report and a medical examination. The medico-legal report indicated a deep-healed laceration consistent with a blunt penetrating trauma, which could not be dated accurately but was more than 21 days old. The defense presented Ramos, his wife, and daughter, who denied the accusations, citing the small size of their house, the presence of dogs, and their acts of kindness towards AAA’s family. The Regional Trial Court convicted Ramos of four counts of rape and sentenced him to reclusion perpetua for each count, with corresponding damages. The Court of Appeals affirmed the decision.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellant Adel Ramos y Abellana for four counts of rape.

RULING

The Supreme Court denied the appeal and affirmed the decision of the Court of Appeals. The Court held that the testimony of AAA was credible, straightforward, and consistent. The medical findings, though not conclusive of recent rape, were consistent with AAA’s account of being first raped in July 2007. The Court found no ill motive for AAA to falsely accuse Ramos. The defense of denial and alibi was weak and could not prevail over the positive identification and credible testimony of the victim. The failure to immediately report the rape was not indicative of falsity, given the threats made by Ramos and the victim’s fear. The award of damages was modified in line with prevailing jurisprudence: civil indemnity was increased to P75,000, moral damages to P75,000, and exemplary damages to P30,000 for each count of rape. All monetary awards were subject to legal interest at 6% per annum from the finality of the judgment until fully paid.