GR 201587; (November, 2012) (Digest)
G.R. No. 201587; November 14, 2012
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. VICTOR LANSANGAN, Accused-Appellant.
FACTS
Accused-appellant Victor Lansangan was convicted of statutory rape against XXX, the granddaughter of his live-in partner, AAA. The prosecution established that the crimes occurred in their residence in Nagtagaan, Rosario, La Union. XXX, who was eight years old at the time of trial, testified that Lansangan, whom she called “Tatay,” inserted his finger and penis into her vagina on multiple occasions when her grandmother was away, causing her pain. She revealed the abuse to AAA during a bath. AAA corroborated the child’s account, stating she reported the matter to the barangay and the DSWD after XXX’s disclosure.
The defense consisted of Lansangan’s denial and alibi. He claimed the accusations were fabricated by AAA out of revenge after their separation due to financial disputes. He asserted that XXX was never left alone with him and that AAA had visited him in jail, suggesting the case would be withdrawn. He presented a letter from AAA asking for money as evidence of her motive to extort him.
ISSUE
Whether the Court of Appeals erred in affirming the conviction of Victor Lansangan for statutory rape based on the testimonies of the child victim and her grandmother.
RULING
The Supreme Court denied the appeal and affirmed the conviction. The Court upheld the credibility of the child victim’s testimony, which was found to be clear, candid, and straightforward. In cases of statutory rape, the victim’s testimony alone, if credible, is sufficient to sustain a conviction. The Court emphasized that the trial court’s assessment of witness credibility is accorded great weight, as it is in a better position to observe their demeanor. XXX’s positive identification of Lansangan as her assailant was deemed credible and unshaken by cross-examination.
The Court rejected Lansangan’s defense of denial and imputation of ill motive on AAA. Denial is inherently weak and cannot prevail over the affirmative and categorical testimony of a credible witness, especially a child victim of tender years. No evidence substantiated the claim that AAA concocted the story out of spite. The alleged financial disputes and visits to jail did not disprove the commission of the crime. The award of damages was modified in accordance with prevailing jurisprudence, and it was clarified that Lansangan, sentenced to reclusion perpetua, is ineligible for parole under Republic Act No. 9346.