GR 224626; (June, 2018) (Digest)
G.R. No. 224626. June 27, 2018.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, V. YYY, ACCUSED-APPELLANT.
FACTS
Accused-appellant YYY was charged with three counts of rape committed against his half-sister, AAA, in 1993 and 1994. The prosecution’s evidence established that on three separate occasions, YYY, through force and intimidation, had carnal knowledge of AAA, who was then nine to ten years old. AAA testified that YYY threatened to kill her if she reported the assaults, which caused her to remain silent for years. She only disclosed the rapes in 2000 upon discovering YYY was also abusing her younger sister. A medical examination revealed healed hymenal lacerations consistent with penetration.
The defense presented a different narrative, alleging that AAA fabricated the charges out of revenge. YYY claimed that in December 1999, he scolded AAA and her companions during a picnic, after which he was mauled by them. He asserted that AAA filed the rape case only after he attempted to file a barangay complaint about the mauling.
ISSUE
Whether the Court of Appeals correctly affirmed the conviction of accused-appellant YYY for three counts of rape.
RULING
The Supreme Court affirmed the conviction. The Court upheld the factual findings of the lower courts, emphasizing that the credibility of the victim-witness is paramount in rape cases. AAA’s testimony was found to be categorical, consistent, and credible. She provided detailed accounts of each incident, which were corroborated by medical findings. The Court ruled that her delay in reporting the crimes was sufficiently explained by the threats on her life, a common reaction for victims, especially minors, who live in fear of their abuser.
The defense of denial and alibi was rejected as inherently weak, especially when weighed against the positive and credible identification by the victim. The alleged motive of revenge was deemed insufficient to overturn the conviction, as no clear and convincing evidence was presented to prove that AAA was actuated by ill will. The elements of rape—carnal knowledge through force or intimidation—were proven beyond reasonable doubt for all three counts. The Court modified the awarded damages, increasing civil indemnity, moral damages, and exemplary damages to ₱100,000.00 each per count, in line with prevailing jurisprudence, all with 6% interest per annum from finality until fully paid.