G.R. No. 200329 ; June 5, 2013
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. RICARDO PIOSANG, Accused-Appellant.

FACTS

Upon a sworn complaint, an Information dated January 8, 1999, was filed charging accused-appellant Ricardo Piosang with the rape of AAA, a minor, on or about July 8, 1998, in Quezon City. The accused pleaded not guilty. The prosecution presented the testimonies of the victim AAA, her mother BBB, a minor witness CCC, CCC’s mother DDD, and a medico-legal officer. The defense presented accused-appellant and his mother, Remedios Piosang.
The prosecution’s evidence established that on July 8, 1998, accused-appellant, through CCC, lured AAA to his house. He then pushed AAA and CCC into a separate comfort room, threatened them with a fan knife, and ordered CCC to hold AAA from behind. Accused-appellant then inserted his penis into AAA’s vagina while she was standing on a toilet bowl. He later forced CCC to pretend to do the same. Accused-appellant threatened to kill them if they reported the incident and gave AAA a five-peso coin, which she discarded. AAA revealed the rape to her mother months later. A medical examination confirmed healed lacerations and AAA’s non-virgin state.
The defense denied the accusation, claiming accused-appellant was at home drying his hair. He alleged that upon being summoned, he went to DDD’s house where he heard CCC crying and admitting to wrongdoing. He suggested that AAA be medically examined. The defense also insinuated an attempt to settle the case for money.
The Regional Trial Court found accused-appellant guilty of rape under Article 266-A of the Revised Penal Code in relation to R.A. 7610 and sentenced him to reclusion perpetua, ordering him to pay civil indemnity, moral damages, and exemplary damages. The Court of Appeals affirmed the conviction with modifications to the amounts of damages.

ISSUE

Whether the trial court gravely erred in finding accused-appellant guilty of rape despite the prosecution’s alleged failure to prove his guilt beyond reasonable doubt.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the Decision of the Court of Appeals with modifications.
The Court held that the findings of fact of the trial court, especially when affirmed by the Court of Appeals, are generally binding and entitled to the highest respect. The trial court is in the best position to assess the credibility of witnesses, having observed their demeanor. There was no cogent reason to depart from this rule.
The testimony of the child-victim, AAA, was given full weight and credit. Her account was direct, candid, and detailed. The Court emphasized that testimonies of child-victims are normally accorded full credence; youth and immaturity are badges of truth. Considering her tender age (four years old at the time of the rape), she could not have fabricated such a story. Her positive identification of accused-appellant as her abuser was consistent and categorical.
The defense’s arguments, including the pointing of blame to CCC, the initial delay in reporting, and the alleged settlement offer, were insufficient to overturn the conviction. The medical findings corroborated the fact of sexual abuse.
The crime was properly qualified as rape under Article 266-A(1)(d) of the Revised Penal Code, as the victim was under twelve years of age. The penalty of reclusion perpetua was affirmed.
The Court modified the awards of damages in line with prevailing jurisprudence. Accused-appellant was ordered to pay the victim: Seventy-five thousand pesos (P75,000.00) as civil indemnity, Seventy-five thousand pesos (P75,000.00) as moral damages, and Thirty thousand pesos (P30,000.00) as exemplary damages. All damages shall earn legal interest at 6% per annum from the finality of the judgment until fully paid.