GR 207513; (June, 2014) (Digest)
G.R. No. 207513, June 16, 2014
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. BRICCIO BACULANTA, Accused-Appellant.
FACTS
On February 27, 2005, in Capoocan, Leyte, accused-appellant Briccio Baculanta, a septuagenarian and a close relative treated as a godfather by the victim’s mother, was left with the 7-year-old victim AAA and her younger brother at their residence. At around noon, Baculanta ordered AAA to fetch water from a nearby river. He followed her, pushed her into the water, ordered her to lie on a rock, undressed her, removed his shorts, and proceeded to have carnal knowledge of her. He threatened her not to report the incident. The following evening, AAA’s mother discovered blood on AAA’s shorts and, upon examination, AAA confided that she was raped by Baculanta. A medical examination conducted on March 1, 2005, revealed redness and swelling of AAA’s labia minora, indicative of penetration. Baculanta denied the accusation, claiming he was drinking with AAA’s stepfather and suggested the stepfather might be the perpetrator. The Regional Trial Court found Baculanta guilty of rape and sentenced him to reclusion perpetua, with damages. The Court of Appeals affirmed the conviction with modifications to the damages.
ISSUE
Whether the Court of Appeals correctly affirmed the conviction of accused-appellant Briccio Baculanta for the crime of rape.
RULING
Yes. The Supreme Court affirmed the decision of the Court of Appeals. The prosecution established all elements of rape under Article 266-A of the Revised Penal Code, as amended. AAA’s credible and straightforward testimony, corroborated by medical findings, proved carnal knowledge. As AAA was under twelve years old at the time of the incident, rape is deemed committed even absent force, threat, or intimidation. The Court upheld the trial court’s assessment of AAA’s credibility, noting that testimonies of young victims are accorded weight, especially when devoid of ill motive. Baculanta’s bare denial, unsupported by evidence and lacking any showing of motive for false accusation, could not overcome the positive identification and detailed account of the victim. The award of damages, including civil indemnity, moral damages, exemplary damages, and legal interest, was sustained.