G.R. No. 214762 SEPTEMBER 20, 2017
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs. ROMMEL RONQUILLO, Accused-Appellant

FACTS

On October 3, 2001, AAA, an eleven-year-old minor, was on her way home after watching a singing contest. While walking, she noticed accused-appellant Rommel Ronquillo at a waiting shed. He approached and offered to accompany her, but she refused. After waiting unsuccessfully for a friend, AAA decided to walk home alone. During her walk, a man accosted her at gunpoint, choked her when she resisted, and threatened to shoot her if she did not comply. The assailant brought her to an isolated area, forced her to raise her blouse over her head to blind her, and covered his own face with a red handkerchief. He then proceeded to rape her. During the assault, AAA recognized the assailant’s maong pants as those worn by accused-appellant earlier at the shed. When the handkerchief fell, she positively identified him as the rapist. She immediately reported the incident to her parents. A medical examination at the UP-PGH Child Protection Unit conducted by Dr. Stella Guerrero-Manalo revealed fresh lacerations on AAA’s hymen, definitive of recent penetrating injury. The defense presented only accused-appellant’s testimony, denying the accusation and claiming he did not know AAA.

ISSUE

Whether the Court of Appeals correctly affirmed accused-appellant’s conviction for statutory rape.

RULING

The Supreme Court affirmed the conviction. The Court emphasized that for statutory rape under Article 266-A of the Revised Penal Code, the prosecution must only prove two elements: (1) that the victim was under twelve years of age, and (2) that the accused had carnal knowledge of her. The victim’s age was conclusively established by her testimony and the Information. Carnal knowledge was proven through AAA’s clear, consistent, and credible testimony detailing the rape, which was corroborated by the medico-legal findings of recent penetrating injury. The Court found AAA’s identification of accused-appellant as the perpetrator to be credible and reliable. Her recognition of his pants and her positive identification when the handkerchief fell were spontaneous and devoid of any ill motive to falsely testify. The defense of denial, being inherently weak, cannot prevail over the positive and categorical testimony of the victim. The Court also upheld the award of damages, modifying them in line with prevailing jurisprudence to P75,000.00 as civil indemnity, P75,000.00 as moral damages, and P75,000.00 as exemplary damages, all with legal interest. The presence of the aggravating circumstance of use of a deadly weapon justified the award of exemplary damages.