G.R. No. 202122 ; January 15, 2014
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. BERNABE PAREJA y CRUZ, Accused-Appellant.

FACTS

The accused-appellant, Bernabe Pareja, was convicted by the Regional Trial Court of Pasay City for two counts of Rape and one count of Attempted Rape against AAA, the 13-year-old daughter of his live-in partner. The incidents occurred in their shared residence in Pasay City in December 2003, February 2004, and March 2004. AAA testified that Pareja, taking advantage of her mother’s absence, sexually assaulted her. The December 2003 incident involved anal penetration, while the February 2004 incident involved acts of lasciviousness. The March 2004 attempted rape was thwarted when AAA’s mother discovered Pareja lifting AAA’s skirt. A medico-legal report from the Philippine General Hospital confirmed blunt force or penetrating trauma to AAA’s genitalia.
Pareja appealed, denying the accusations and arguing that the crimes were impossible to commit in their small, crowded house without alerting AAA’s siblings or neighbors. He claimed AAA had a motive to fabricate the charges due to his strictness. The Court of Appeals affirmed the RTC’s conviction for Rape (Criminal Case No. 04-1557-CFM for the December 2003 incident) and Acts of Lasciviousness (Criminal Case No. 04-1556-CFM for the February 2004 incident). However, it acquitted him of Attempted Rape (Criminal Case No. 04-1558-CFM) due to reasonable doubt, as the prosecution failed to prove his intent to have carnal knowledge during the March 2004 incident.

ISSUE

The core issue before the Supreme Court was whether the Court of Appeals erred in affirming Pareja’s conviction for Rape and Acts of Lasciviousness.

RULING

The Supreme Court denied the appeal and affirmed the convictions. The Court upheld the factual findings of the lower courts, emphasizing that the credibility of the victim-witness is paramount in rape cases. AAA’s candid, consistent, and unwavering testimony, corroborated by the medico-legal findings, constituted proof beyond reasonable doubt. The Court found her account of the December 2003 anal rape credible, noting that rape can be committed through anal intercourse. Her delay in reporting was sufficiently explained by Pareja’s threats to kill her, a common reaction from a young victim living under the same roof as her abuser.
The Court rejected Pareja’s defense of impossibility and denial as weak and self-serving. It ruled that lust is no respecter of time and place, and rape can be committed even in small, crowded dwellings when the perpetrator finds an opportunity. His claim of ill motive was unsubstantiated. The acquittal for Attempted Rape was also sustained, as the prosecution did not establish that his acts in March 2004 were unequivocally directed at having carnal knowledge. The penalty for Rape was modified to reclusion perpetua without eligibility for parole, and damages were awarded to the victim.