GR 219088; (June, 2018) (Digest)
G.R. No. 219088, June 13, 2018
People of the Philippines, Plaintiff-Appellee vs. Ronnie Dela Cruz a.k.a. “Barok”, Accused-Appellant
FACTS
The accused-appellant, Ronnie Dela Cruz, was charged with the rape of AAA, a 14-year-old minor, on April 4, 2008. The prosecution evidence established that AAA and her aunt, BBB, were drinking at a friend’s house when Dela Cruz arrived. As AAA was sleepy and did not want to go home, BBB asked Dela Cruz if AAA could sleep at his nearby house. Dela Cruz agreed and accompanied AAA to his home. Once inside an unlit room, Dela Cruz kissed AAA, removed her clothes despite her pleas and attempts to push him away, and then had sexual intercourse with her. AAA cried during the act. She left the next morning and later reported the incident, leading to a medical examination that confirmed fresh hymenal lacerations.
The defense presented Dela Cruz as its sole witness. He admitted being with AAA that night but claimed any sexual act was consensual, suggesting both were intoxicated. He asserted that AAA’s parents fetched her from his house the following afternoon.
ISSUE
Whether the Court of Appeals correctly affirmed the conviction of accused-appellant Ronnie Dela Cruz for the crime of rape.
RULING
The Supreme Court affirmed the conviction. The Court upheld the findings of the lower courts that the prosecution proved the elements of rape under Article 266-A of the Revised Penal Code beyond reasonable doubt. AAA’s categorical, consistent, and straightforward testimony, corroborated by the medical findings of fresh hymenal laceration, sufficiently established carnal knowledge. The Court emphasized that the force or intimidation in rape is relative and need not be overpowering; it is sufficient if it brings about the desired result. AAA’s resistance, through her pleas and physical pushing, was overcome by Dela Cruz’s actions. Her intoxication did not negate the presence of force but instead rendered her less capable of offering effective resistance.
The Court rejected Dela Cruz’s defense of denial and claim of consensual sex. Denial is inherently weak against positive identification and credible testimony. His claim of consent was belied by AAA’s immediate conduct of reporting the rape and the medical evidence. The Court modified the awarded damages, increasing civil indemnity, moral damages, and exemplary damages to Seventy-Five Thousand Pesos (Php75,000.00) each, in line with prevailing jurisprudence, all with legal interest from finality of judgment until fully paid.