GR 215194; (December, 2017) (Digest)
G.R. No. 215194 , December 14, 2017
People of the Philippines, Plaintiff-Appellee vs. Ron Aldo Deloso y Ba Gares, Accused-Appellant
FACTS
The accused-appellant, Ron Aldo Deloso, was convicted of qualified rape against AAA, the 13-year-old daughter of his common-law spouse, BBB. The prosecution established that on September 16, 2009, at midnight in their home, Deloso, while wearing only a shirt, removed AAA’s clothing and had carnal knowledge of her. AAA’s 11-year-old brother, CCC, witnessed the assault, having been moved by Deloso from beside AAA to near the door. CCC testified to seeing Deloso on top of AAA making push-and-pull movements while AAA cried. After the act, CCC ran to report the crime to their aunt and the barangay, leading to Deloso’s arrest. AAA revealed this was not an isolated incident, as Deloso had sexually abused her multiple times before, threatening to kill her family if she reported him.
The Regional Trial Court found Deloso guilty beyond reasonable doubt and sentenced him to reclusion perpetua without parole. The Court of Appeals affirmed this decision. Deloso appealed to the Supreme Court, arguing the prosecution failed to prove his guilt and that the testimonies of AAA and CCC were inconsistent and incredible.
ISSUE
Whether the Court of Appeals erred in affirming Deloso’s conviction for qualified rape based on the alleged inconsistencies in the testimonies of the victim and the child witness.
RULING
The Supreme Court denied the appeal and affirmed the conviction. The Court held that minor inconsistencies in the testimonies of AAA and CCC, particularly regarding the exact positioning during the assault and the lighting conditions, did not undermine their credibility. Instead, such minor variances were indicative of truthful, unrehearsed narration. The core elements of rape were convincingly established: Deloso had carnal knowledge of AAA, a minor, through force and intimidation, and he was the common-law spouse of AAA’s mother, a qualifying circumstance under Article 266-B of the Revised Penal Code.
The Court emphasized that the testimonies of child victims are given full weight and credit, as youth and immaturity generally make them incapable of fabricating tales of sexual abuse. The detailed and categorical accounts of both AAA and CCC, corroborated by the prompt reporting of the crime, left no doubt as to Deloso’s guilt. The qualifying circumstance of the accused being the common-law spouse of the victim’s parent was sufficiently proven, warranting the imposition of reclusion perpetua without eligibility for parole. The award of damages was also affirmed with modifications, including civil indemnity, moral damages, and exemplary damages, all with legal interest.