G.R. No. 218277, November 09, 2020
The People of the Philippines, Plaintiff-Appellee, v. XXX, Accused-Appellant.

FACTS

Accused-appellant was charged with the statutory rape of his daughter, AAA, a nine-year-old minor, on March 22, 2008, in Quezon City. The prosecution’s evidence established that on said date, while AAA’s mother was out, accused-appellant instructed AAA to go to a bedroom, ordered her to remove her shorts, and inserted his penis into her vagina, causing her pain. AAA shouted and pleaded for him to stop, which he did, but he threatened her not to tell her mother. The following day, after a quarrel where accused-appellant banished AAA’s mother from their home, AAA, fearing her mother’s departure, disclosed the rape and revealed that her father had been sexually assaulting her since she was five years old. This led to a police report and a medico-legal examination.
The defense presented a denial and alibi, claiming accused-appellant was elsewhere at the time. The Regional Trial Court convicted accused-appellant of statutory rape, a decision affirmed by the Court of Appeals. The CA held that AAA’s credible testimony, coupled with her minority, sufficiently proved the crime. The case was elevated to the Supreme Court via an appeal.

ISSUE

Whether the Court of Appeals erred in affirming accused-appellant’s conviction for statutory rape.

RULING

The Supreme Court denied the appeal and affirmed the conviction. The legal logic centers on the elements of statutory rape under Article 266-A(1)(d) of the Revised Penal Code, as amended: (1) sexual intercourse with a woman; (2) who is under 12 years of age. Proof of force, intimidation, or consent is immaterial; the crime is consummated by carnal knowledge of a child below 12. The prosecution conclusively established AAA’s age as nine years old through her birth certificate. Regarding the act of sexual intercourse, the Court clarified that full penetration of the vagina is not required; even the slightest penetration of the labia or entry into the vulva constitutes carnal knowledge.
The Court found AAA’s testimony credible, straightforward, and consistent. Her delay in disclosure was satisfactorily explained by her fear of her father’s threats against her mother. The medico-legal findings, while indicating an intact hymen, corroborated her account, as the physician testified that the injuries were consistent with blunt force trauma to the genital area, which could include attempted penetration. The defense of denial and alibi, inherently weak and uncorroborated, could not prevail over the positive identification and credible testimony of the victim. Thus, all elements of statutory rape were proven beyond reasonable doubt. The penalties and awards of damages were affirmed with modification, imposing interest on all monetary awards.