GR 209344; (June, 2016) (Digest)
G.R. No. 209344 June 27, 2016
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. JAIME BRIOSO alias TALAP-TALAP, Accused-Appellant.
FACTS
On May 31, 2001, four-year-old AAA was playing near her home when accused-appellant Jaime Brioso approached her. He lured her to a nearby mango tree with a promise of candies. There, he removed her clothing, mashed her private organ, inserted his finger into her vagina, and then proceeded to have carnal knowledge of her. After the act, Brioso threatened to kill her if she told anyone. AAA, stricken with fear, went home without reporting the incident. The following morning, her mother BBB noticed her difficulty in urinating and discovered swelling in her genital area. Upon questioning, AAA revealed that Brioso had molested her.
BBB immediately reported the crime to a barangay official, leading to a formal complaint at the police station and a medico-legal examination. An Information for statutory rape was filed. Brioso was eventually arrested in 2007. During trial, he denied the accusation and raised the defense of alibi. The Regional Trial Court found him guilty beyond reasonable doubt of statutory rape under Article 266-A(1)(d) of the Revised Penal Code in relation to Republic Act No. 7610 , sentencing him to reclusion perpetua. The Court of Appeals affirmed the conviction in toto.
ISSUE
Whether the Court of Appeals erred in affirming accused-appellant’s conviction for statutory rape.
RULING
The Supreme Court denied the appeal and affirmed the conviction. The Court held that all elements of statutory rape were proven beyond reasonable doubt. AAA, who was only four years old at the time of the crime, was below the age of twelve, making her incapable of giving legal consent. Her credible and straightforward testimony, corroborated by the medico-legal findings of hymenal laceration, sufficiently established carnal knowledge. The Court emphasized that the testimony of a child-victim, when credible, is sufficient to sustain a conviction. The delay in reporting the incident, attributed to the accused’s death threat, did not impair AAA’s credibility, as such reaction is understandable for a young child. The defense of alibi was correctly rejected, as Brioso failed to prove it was physically impossible for him to be at the crime scene. The positive identification by the victim prevails over a weak alibi. The penalty of reclusion perpetua without eligibility for parole was correctly imposed, in accordance with prevailing jurisprudence for statutory rape. The awarded damages were also affirmed as proper.