GR 217975; (November, 2015) (Digest)
G.R. No. 217975, November 23, 2015
People of the Philippines, Plaintiff-Appellee, vs. Bernardino Biala, Accused-Appellant.
FACTS
Accused-appellant Bernardino Biala was charged with three counts of rape committed against AAA, his ward, in November 1999 (Criminal Case No. 1990), on a successive night in November 1999 (Criminal Case No. 2220), and in June 2001 (Criminal Case No. 2221). AAA testified that during the first incident, Biala removed her clothes, kissed her, punched her abdomen, and when she regained consciousness, she was naked, felt vaginal pain, and saw blood. For the second incident, Biala led her to a bedroom, undressed her, punched her, and had forcible sexual intercourse while threatening her with a gun. In the third incident, Biala pulled her dress, pushed her onto a bed, undressed her, and had sexual intercourse twice, again issuing threats. AAA eventually reported the incidents to the police with the help of neighbors. A medical examination revealed a healed hymenal laceration. Biala denied the accusations, claiming AAA was elsewhere during the alleged incidents and that the charges were fabricated due to a grudge over a debt.
ISSUE
The primary issue was whether the Court of Appeals correctly affirmed Biala’s convictions for Statutory Rape and Qualified Rape, and modified his conviction from Attempted Rape to Acts of Lasciviousness for the first incident.
RULING
The Supreme Court denied the appeal and affirmed the Decision of the Court of Appeals with modifications to the awards of damages. The CA affirmed Biala’s convictions for Statutory Rape in Criminal Case No. 2220 and Qualified Rape in Criminal Case No. 2221, but modified his conviction in Criminal Case No. 1990 from Attempted Rape to Acts of Lasciviousness. The Court found AAA’s testimony credible, consistent, and corroborated by medical evidence. It rejected Biala’s defenses of denial and alibi as weak and uncorroborated. For Criminal Case No. 1990, the Court agreed with the CA that the prosecution failed to prove commencement of sexual penetration, essential for Attempted Rape, but that his acts constituted Acts of Lasciviousness. The penalties imposed by the CA were affirmed: for Acts of Lasciviousness, an indeterminate penalty; for Statutory Rape, reclusion perpetua; and for Qualified Rape, reclusion perpetua. The Court increased the awards of civil indemnity, moral damages, and exemplary damages for the rape convictions in line with prevailing jurisprudence.