G.R. No. 206294 , June 29, 2016
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. CERILO “ILOY” ILOGON, Accused-Appellant.

FACTS

On December 15, 2002, six-year-old AAA was playing with her cousins on the roof of her aunt’s house. She was left crying after being unable to climb down. The accused-appellant, Cerilo “Iloy” Ilogon, a neighbor, helped her down but instead brought her to his house. There, he removed his clothes, covered her mouth, kissed her, and had carnal knowledge of her. AAA felt pain and cried. She later ran home and complained to her mother, BBB, of bodily aches and pain in her genitalia, which appeared reddish. The following day, BBB learned the details from AAA’s cousins and confirmed the incident with AAA. A medical examination revealed healed hymenal lacerations.
The accused-appellant was charged with qualified rape. He pleaded not guilty, interposing the defense of denial. He admitted helping AAA down but denied the rape, a claim corroborated by his wife and three neighbors. The Regional Trial Court found him guilty beyond reasonable doubt of qualified rape and sentenced him to reclusion perpetua, awarding civil indemnity and moral damages. The Court of Appeals affirmed the conviction but modified the damages awarded.

ISSUE

Whether the Court of Appeals correctly affirmed the conviction of the accused-appellant for the crime of qualified rape.

RULING

The Supreme Court affirmed the conviction. The case involves statutory rape under Article 266-A(1)(d) of the Revised Penal Code, as amended. Sexual intercourse with a woman below twelve years of age is always rape, as the law presumes she cannot give intelligent consent. The prosecution successfully proved the three elements: (1) AAA was six years old, as established by her testimony and the stipulation during pre-trial; (2) the identity of the accused-appellant as the perpetrator, positively identified by AAA; and (3) sexual intercourse occurred, corroborated by AAA’s credible testimony and the medical findings of healed hymenal lacerations.
The Court upheld the consistent findings of the lower courts regarding AAA’s credibility. A young victim’s testimony, given in a straightforward and candid manner, deserves full credence. The defense of denial, being inherently weak, cannot prevail over the positive identification and credible testimony of the victim. The qualifying circumstance of the victim being under seven years old was also duly proven, warranting the penalty of reclusion perpetua, as the death penalty is prohibited. The Supreme Court further modified the damages, awarding P100,000 each as civil indemnity, moral damages, and exemplary damages, with legal interest.