GR 212337; (July, 2016) (Digest)
G.R. No. 212337 , July 4, 2016
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. BELTRAN FUENTES, JR., Accused-Appellant.
FACTS
The accused-appellant, Beltran Fuentes, Jr., was convicted by the Regional Trial Court of rape against his 14-year-old niece, AAA. The prosecution established that on the evening of April 30, 2002, in Basay, Negros Oriental, AAA was defecating near her home when Fuentes grabbed her, forced her to lie down, and had carnal knowledge with her against her will. AAA immediately reported the incident to her parents, leading to a medical examination which confirmed lacerations in her hymen. Despite initially executing an Affidavit of Desistance, which she later renounced in court, AAA provided a consistent and categorical testimony detailing the rape.
Fuentes denied the accusation, presenting an alibi that he was doing carpentry work at AAA’s parents’ house until 5:00 p.m. and was at home during the alleged incident. He claimed AAA’s identification was unreliable as it was based merely on recognizing his voice. The trial court found him guilty beyond reasonable doubt, imposing the death penalty, which the Court of Appeals modified to reclusion perpetua without parole eligibility under Republic Act No. 9346 . Fuentes appealed to the Supreme Court, challenging AAA’s credibility and the improbability of her testimony.
ISSUE
Whether the Court of Appeals erred in affirming the conviction of the accused-appellant for the crime of rape.
RULING
The Supreme Court affirmed the conviction. The Court emphasized the well-settled principle that factual findings of the trial court, especially on witness credibility, are accorded great weight and respect on appeal. The trial judge is in the best position to assess the demeanor and sincerity of witnesses, an advantage not available to appellate courts. AAA’s testimony was found to be clear, consistent, and credible. Her detailed account of the sexual assault, corroborated by the medical certificate showing hymenal lacerations, constituted proof beyond reasonable doubt.
The Court dismissed the defense of alibi and denial as weak and unsubstantiated, especially when juxtaposed with AAA’s positive identification of Fuentes as her assailant. The Affidavit of Desistance was rightly disregarded, as AAA credibly explained in court that she was induced to sign it by Fuentes’s wife with a promise of educational support. Retractions are generally viewed with suspicion and do not automatically nullify a prior testimony given in open court. The crime was qualified as statutory rape due to AAA’s minority, and the relationship of affinity was correctly considered as an aggravating circumstance. The penalty of reclusion perpetua without eligibility for parole was upheld. Civil indemnity, moral damages, and exemplary damages were increased to P100,000.00 each, with 6% interest per annum from finality until fully paid.