G.R. No. 218114 June 5, 2017
People of the Philippines, Plaintiff-Appellee vs. Salvador Aycardo, Accused-Appellant

FACTS

The accused-appellant, Salvador Aycardo, was charged with Acts of Lasciviousness and Qualified Rape against his niece, AAA, who was eleven years old at the time of the incidents in September 2007. AAA was then living in Aycardo’s house under the care of his wife, who was AAA’s aunt. The prosecution evidence established that one afternoon, Aycardo entered AAA’s room, attempted to remove her clothing, and touched her vagina with his finger. Later that same evening, after AAA had returned to the house, Aycardo raped her by having carnal knowledge while she slept, threatening to kill her if she told anyone. The crime was revealed in March 2008 when AAA cried out in her sleep, prompting her mother to inquire and subsequently report the incidents.
The defense presented denial and alibi. Aycardo claimed AAA lived with her mother 100 meters away and denied she worked as a helper in his house or that he committed the acts. He asserted he was at his farm during the alleged incidents. The Regional Trial Court convicted Aycardo of Acts of Lasciviousness and Qualified Rape, a decision affirmed with modification by the Court of Appeals.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused-appellant for the crimes charged beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The Court found AAA’s testimony to be credible, straightforward, and consistent. The medical examination corroborated her account, revealing “clear sign of blunt vaginal penetrating trauma.” The Court emphasized that in rape cases, the victim’s testimony, if credible, is sufficient to sustain a conviction. AAA’s detailed narration of the two separate incidents—the lascivious act in the afternoon and the rape at night—was deemed natural and convincing.
The Court rejected the defense of denial and alibi for being inherently weak and unsubstantiated by clear and convincing evidence. It held that these defenses cannot prevail over the positive and categorical identification by the victim. Furthermore, the qualifying circumstance of relationship was duly alleged in the Information and proven, as Aycardo was the victim’s uncle by affinity. The Court also affirmed the penalty imposed by the CA: for Qualified Rape, reclusion perpetua without eligibility for parole, and for Acts of Lasciviousness, an indeterminate penalty. The awards of damages were modified in accordance with prevailing jurisprudence.