GR 208646; (June, 2016) (Digest)
G.R. No. 208646 . June 15, 2016.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. LORETO SONIDO Y CORONEL, ACCUSED-APPELLANT.
FACTS
The accused-appellant, Loreto Sonido y Coronel, was charged with the rape of his eight-year-old niece, AAA. The prosecution established that on December 29, 2004, AAA was sleeping in the sala of the appellant’s house when she awoke to find herself undressed with the appellant on top of her. He removed her underpants and inserted his penis into her vagina, causing her pain. The act was repeated, after which the appellant threatened her and her family’s life. AAA reported the incident to a neighbor, who brought her to the barangay captain. A medical examination conducted about twelve hours later yielded normal genital findings, but the examining physician explained that any abrasions could have healed due to the vascular nature of the area and the time lapse. The appellant denied the allegations, claiming the charge was fabricated due to a prior dispute with the neighbor.
ISSUE
Whether the Court of Appeals correctly affirmed the conviction of the accused-appellant for the crime of statutory rape.
RULING
Yes, the conviction is affirmed. The crime charged is statutory rape under Article 266-A(1)(d) of the Revised Penal Code, as amended. In statutory rape, carnal knowledge of a woman below twelve years of age is punishable by reclusion perpetua. The law presumes the victim incapable of giving intelligent consent; thus, proof of force, intimidation, or lack of consent is unnecessary. The prosecution successfully proved the two essential elements: the age of the complainant and the fact of sexual intercourse. AAA’s birth certificate conclusively established she was eight years old at the time of the incident. Her clear, candid, and consistent testimony, despite rigorous cross-examination, sufficiently established the fact of carnal knowledge. The Court found her testimony credible, as the testimony of a child-victim is given full weight and credit. The normal medical findings do not negate the commission of rape, as the physician credibly explained the possibility of healing. The defense of denial and alleged ill motive of a witness cannot prevail over the positive identification and credible testimony of the victim. The Supreme Court modified the damages awarded, increasing the civil indemnity, moral damages, and exemplary damages to Seventy-Five Thousand Pesos (₱75,000.00) each, with interest at 6% per annum from finality until fully paid.