G.R. No. 200529; September 19, 2012
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. JUANITO GARCIA y GUMAY @ WAPOG, Accused-Appellant.

FACTS

The accused-appellant, Juanito Garcia, was charged with three counts of statutory rape against his eight-year-old cousin, AAA, occurring on April 30, May 1, and May 2, 2001. During trial, AAA, who was eleven at the time of her testimony, provided a detailed and consistent account of the assaults. She testified that on April 30, Juanito, armed with an axe and smelling of alcohol, forcibly raped her inside her aunt’s house. On May 1, he touched her vagina, and on May 2, he again inserted his penis into her vagina. Her testimony was corroborated by the medical findings of Dr. Florentina Vergara, who confirmed a healed hymenal laceration consistent with penile penetration. The defense consisted of a denial and an allegation of ill-motive, claiming the charges were fabricated due to a family feud over inheritance.
The Regional Trial Court convicted Juanito of one count of statutory rape for the April 30 incident and one count of acts of lasciviousness for the May 1 incident, while acquitting him of the May 2 rape charge due to reasonable doubt. The Court of Appeals affirmed this decision. The case was elevated to the Supreme Court for automatic review.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused-appellant for statutory rape and acts of lasciviousness beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction with modifications to the awarded damages. The Court upheld the credibility of AAA’s testimony, which was straightforward, candid, and consistent with human experience. The testimony of a child victim, when credible, is sufficient to sustain a conviction. The medical findings, though noting an absence of spermatozoa, corroborated her account by confirming a healed laceration indicative of prior penetration. The Court emphasized that the defense of denial and imputation of ill-motive cannot prevail over the positive and credible identification by the victim. The alleged family feud was deemed insufficient to motivate an eight-year-old to fabricate a story of rape and undergo the ordeal of a trial.
Regarding the penalties, for statutory rape under Article 266-B of the Revised Penal Code, the penalty of reclusion perpetua was affirmed. For acts of lasciviousness under Article 336, the indeterminate penalty of six months of arresto mayor as minimum to four years and two months of prision correccional as maximum was imposed. The Court also modified the damages awarded, increasing them in line with prevailing jurisprudence to provide full civil liability. The awards for the rape conviction were set at ₱50,000.00 civil indemnity, ₱50,000.00 moral damages, and ₱30,000.00 exemplary damages. For acts of lasciviousness, the awards were set at ₱20,000.00 civil indemnity, ₱30,000.00 moral damages, and ₱2,000.00 exemplary damages.