GR 213390; (March, 2017) (Digest)
G.R. No. 213390 . March 15, 2017.
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. JESSIE GABRIEL y GAJARDO, Accused-Appellant.
FACTS
The accused-appellant, Jessie Gabriel y Gajardo, was charged with the rape of “AAA,” a 17-year-old minor. The incident occurred on February 17, 2010, in Dagupan City. “AAA,” a nursing student and boarder in the appellant’s boarding house, testified that the appellant summoned her to his room under the pretext of confronting her about alleged theft from his store. Inside the room, he accused her, threatened to file a police report, and then forced her to sit on his lap. Despite her protests, he pulled her back when she tried to leave, unhooked her bra, made her lie down, and proceeded to have carnal knowledge with her. She cried and expressed her non-consent, but he persisted for about thirty minutes until interrupted by his child knocking on the door. “AAA” immediately reported the rape to her aunt, leading to the appellant’s arrest. A medico-legal examination confirmed recent hymenal lacerations consistent with sexual abuse.
The appellant denied the accusation, claiming he only confronted “AAA” about the missing items. The Regional Trial Court found him guilty of rape and sentenced him to reclusion perpetua. The Court of Appeals affirmed the conviction but modified the damages awarded.
ISSUE
Whether the Court of Appeals correctly affirmed the conviction of the accused-appellant for the crime of rape.
RULING
Yes, the Supreme Court affirmed the conviction. The Court upheld the factual findings of the lower courts, emphasizing that the testimony of the victim, “AAA,” was direct, positive, categorical, and consistent. Her detailed account of the forcible assault, coupled with her immediate report and the corroborative medico-legal findings, established the elements of rape through force and intimidation beyond reasonable doubt. The Court reiterated the doctrine that the testimony of a rape victim, if credible, is sufficient to sustain a conviction.
The appellant’s defense of denial was inherently weak and could not prevail over the clear and convincing testimony of the victim. Denial, unsupported by strong evidence, is insufficient to overcome affirmative testimony. The Court found no reason to deviate from the lower courts’ assessment of witness credibility.
However, the Court modified the civil liabilities in line with prevailing jurisprudence. The awards for civil indemnity, moral damages, and exemplary damages were increased to Seventy-Five Thousand Pesos (Php75,000.00) each, all with legal interest. The penalty of reclusion perpetua was affirmed.