G.R. No. 208007 , April 2, 2014.
PEOPLE OF THE PHILIPPINES, Plaintiff-appellee, vs. RODRIGO GUTIEREZ Y ROBLES ALIAS “ROD AND JOHN LENNON”, Accused-appellant.

FACTS

An Information was filed on November 30, 2005, charging accused-appellant Rodrigo Gutierez with statutory rape for having carnal knowledge of AAA, a 10-year-old Grade 2 student, on or about November 29, 2005, in Baguio City. Upon arraignment, he pleaded not guilty. The prosecution presented AAA, who testified that on the said date, while on her way home from school, she met the accused-appellant, whom she called “Uncle Rod,” at his house. He brought her to his room, laid her on a bed, raised her skirt, removed her panties, pulled down his pants, and inserted his penis into her vagina. The act was painful and caused her to cry. After withdrawing, a white liquid came out of his penis, and he gave her five pesos before she returned to school. AAA further disclosed this happened about ten times on separate occasions, with the accused giving her five or ten pesos each time. Her tardiness prompted her teacher to inquire, leading to the discovery of the incident. A medical examination revealed blunt force penetrating trauma consistent with sexual abuse. The defense consisted of denial, with the accused-appellant claiming he was at work and suggesting AAA’s failure to cry for help, despite her house being nearby, cast doubt on her story. The Regional Trial Court convicted him of statutory rape and sentenced him to reclusion perpetua, with damages. The Court of Appeals affirmed the conviction.

ISSUE

Whether the prosecution was able to prove beyond reasonable doubt that the accused-appellant was guilty of statutory rape punishable under Article 266-A of the Revised Penal Code.

RULING

Yes. The Supreme Court affirmed the conviction. The elements of statutory rape under Article 266-A(1)(d) are: (1) the offended party is under twelve years of age, and (2) the accused has carnal knowledge of her. The first element was proven by AAA’s birth certificate. The second element was established by AAA’s clear, categorical, and credible testimony detailing the sexual act. The Court emphasized that the testimonies of child-victims are given full weight and credence. The medical findings corroborated her account. The accused-appellant’s claim that AAA’s failure to cry for help created reasonable doubt was rejected, as such behavior is not uncommon for a child victim intimidated by a trusted elder. The defense of denial cannot prevail over the positive identification and credible testimony of the victim. The penalty of reclusion perpetua was affirmed. The Court modified the awards of damages, ordering the accused-appellant to pay AAA P100,000.00 as civil indemnity, P100,000.00 as moral damages, and P100,000.00 as exemplary damages, all with legal interest of 6% per annum from the finality of the decision until fully satisfied.