G.R. No. 218584, APRIL 25, 2018
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. DENNIS MANALIGOD Y SANTOS, Accused-Appellant
FACTS
Accused-appellant Dennis Manaligod was charged with statutory rape for having carnal knowledge of AAA, an eight-year-old minor, on September 24, 2007. The prosecution established that AAA’s mother, BBB, discovered the incident after AAA returned from borrowing a charger at a videoke bar with ₱20.00. Upon questioning, AAA revealed that Manaligod brought her to a room, undressed her, inserted his penis into her vagina, gave her money, and instructed her to keep silent. BBB reported the crime, leading to a medical examination which revealed an old hymenal laceration. The defense opted not to present evidence.
The Regional Trial Court convicted Manaligod of statutory rape, a decision affirmed by the Court of Appeals with modifications to the awarded damages. Manaligod appealed to the Supreme Court, questioning the sufficiency of evidence and alleging inconsistencies in the testimonies regarding the time of the incident and the medical findings.
ISSUE
Whether the guilt of the accused-appellant for statutory rape has been proven beyond reasonable doubt.
RULING
Yes. The Supreme Court denied the appeal and affirmed the conviction. The Court clarified that statutory rape under Article 266-A of the Revised Penal Code is committed by sexual intercourse with a woman below twelve years of age, where consent is immaterial. The prosecution successfully proved the three essential elements: (1) AAA was eight years old per her Certificate of Live Birth; (2) AAA positively identified Manaligod in court as her assailant; and (3) sexual intercourse occurred, as detailed in AAA’s credible and consistent testimony describing penetration.
The Court dismissed the alleged inconsistencies as trivial, noting that minor discrepancies on collateral matters do not undermine the credibility of a witness, especially a child victim. The medical finding of an “old” laceration was consistent with the act of penetration and did not negate the rape, as even slight penetration is sufficient. The defense’s failure to present evidence further weakened its case. The Court sustained the penalty of reclusion perpetua without parole and adjusted the damages in line with prevailing jurisprudence, awarding ₱75,000.00 each as civil indemnity, moral damages, and exemplary damages.