G.R. No. 223708 . June 28, 2017.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, V. NORIETO MONROYO Y MAHAGUAY, ACCUSED-APPELLANT.

FACTS

Accused-appellant Norieto Monroyo, the uncle of the victims, was charged with three counts of Acts of Lasciviousness against his 14-year-old niece, AAA, and one count of Qualified Rape against his 16-year-old niece, BBB. The prosecution alleged that on three separate occasions in August and October 2003, Monroyo touched AAA’s private parts inside her home and his own, using force and intimidation. For the rape charge, it was alleged that on November 18, 2003, Monroyo entered the victims’ home at night, forced BBB to lie on the floor, and had carnal knowledge of her while threatening her. BBB later revealed the incident to her mother, and a medical examination revealed healed hymenal lacerations. Monroyo denied the accusations, claiming the charges were fabricated after a trivial dispute over money.
The Regional Trial Court found Monroyo guilty beyond reasonable doubt of all charges. The Court of Appeals affirmed the RTC’s decision in toto. Monroyo appealed to the Supreme Court, arguing that the prosecution failed to prove his guilt beyond reasonable doubt and questioning the credibility of the victims’ testimonies.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellant Norieto Monroyo for three counts of Acts of Lasciviousness and one count of Qualified Rape.

RULING

The Supreme Court denied the appeal and affirmed the conviction. The Court emphasized that findings of fact of the trial court, especially on the credibility of witnesses, are accorded great weight and respect. It found no reason to deviate from the consistent findings of the lower courts. The testimonies of AAA and BBB were found to be credible, straightforward, and consistent on material points, thereby satisfying the quantum of proof required for conviction. The Court held that the victims’ detailed and candid narrations of the traumatic events, coupled with BBB’s medical certificate, constituted strong evidence of guilt.
Regarding the rape charge, the Court ruled that all elements were present: carnal knowledge was proven through BBB’s positive testimony and the medical findings, and it was accomplished through force and intimidation as Monroyo threatened her. The qualifying circumstances of minority and relationship were also duly proven through BBB’s birth certificate and testimonial evidence establishing Monroyo as a relative within the third civil degree by affinity. The defense of denial and frame-up was inherently weak and could not prevail over the positive and credible identification by the victims. The Court modified the awards of damages in line with prevailing jurisprudence but sustained the prison sentences.