GR 200531; (December, 2012) (Digest)
G.R. No. 200531 ; December 5, 2012
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. RADBY ESTOYA y MATEO, Accused-Appellant.
FACTS
The accused-appellant, Radby Estoya, was charged with the rape of AAA, a 14-year-old minor. The prosecution evidence established that on April 5, 2006, AAA was staying at her aunt’s house. While she was sleeping, she was awakened by Estoya on top of her. He threatened her with a knife, undressed her, and proceeded to have carnal knowledge against her will. After the act, Estoya fled. AAA’s brother and a neighbor later found her crying. She was medically examined, and the medico-legal report confirmed a fresh hymenal laceration and evidence of penetrating trauma.
The defense consisted solely of Estoya’s denial and alibi. He claimed he was merely cleaning his house at the time and was not close to the victim. He argued that the prosecution’s evidence was riddled with inconsistencies, such as discrepancies in a witness’s statement about what he saw, the hearsay nature of the aunt’s testimony, the improbability of his unnoticed entry into the house, and AAA’s lack of tenacious resistance during the alleged attack.
ISSUE
Whether the Court of Appeals erred in affirming the conviction of the accused-appellant for rape based on the credibility of the prosecution witnesses and the sufficiency of the evidence proving his guilt beyond reasonable doubt.
RULING
The Supreme Court denied the appeal and affirmed the conviction. The Court emphasized the well-entrenched doctrine that factual findings of the trial court, especially on witness credibility, are accorded great weight and respect. The trial judge is in the best position to observe the witnesses’ demeanor. The Court found no reason to deviate from these findings, as the alleged inconsistencies raised by the defense were minor and did not affect the core narrative of the crime.
The Court held that the victim’s credible testimony, corroborated by the medico-legal findings of recent hymenal injury, was sufficient to establish the elements of rape. The defense of denial and alibi, uncorroborated and weak, could not prevail over the positive identification by the victim. The Court also ruled that the victim’s reaction—being subdued by fear due to a knife threat—was consistent with human experience and did not negate the absence of consent. The award of damages was modified in line with prevailing jurisprudence, granting civil indemnity, moral damages, and exemplary damages.