G.R. No. 225065 . September 13, 2017.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, V. ARMANDO LABRAQUE A.K.A. “ARMAN”, ACCUSED-APPELLANT.

FACTS

The prosecution alleged that on January 26, 2008, in Las Piñas City, accused-appellant Armando Labraque raped AAA, a 12-year-old minor. AAA testified that Labraque, a neighbor, lured her to the second floor of an unfinished building under the pretense of having her sweep. There, while intoxicated, he undressed, forced her to undress, and pinned her down. He forcibly inserted his penis into her vagina despite her cries of pain. He threatened her to keep quiet. Afterward, AAA noticed blood in her underwear and immediately reported the rape to her mother, BBB. The following day, BBB reported the crime to barangay officials, who apprehended Labraque. At the barangay hall, in the presence of AAA and the tanods, Labraque admitted to the act, stating, “opo, isang beses ko long po ginalaw.” A medico-legal examination revealed a deep-healed laceration on AAA’s hymen, consistent with prior penetration, but found no external signs of physical trauma.
The defense consisted solely of Labraque’s testimony, where he denied the accusation and presented an alibi. He claimed he was in Samar at the time of the incident and only traveled to Las Piñas days later. He asserted that his admission before the barangay officials was coerced. The Regional Trial Court convicted him of rape under Article 266-A of the Revised Penal Code in relation to RA 7610, a decision affirmed with modifications by the Court of Appeals. Labraque appealed to the Supreme Court.

ISSUE

The core issue is whether the prosecution proved Labraque’s guilt for the crime of rape beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The Court held that AAA’s testimony was credible, categorical, and consistent. Her detailed account of the rape, including the use of force and intimidation, was sufficient to establish the elements of the crime. The Court emphasized that in rape cases, the victim’s testimony, if credible, is paramount. The lack of external physical injuries does not negate rape, as victims react differently to sexual violence; some may be too terrified to offer physical resistance. The medico-legal finding of a healed laceration, while indicating prior sexual experience, does not disprove the recent rape, as such evidence is merely corroborative and not indispensable for conviction.
Labraque’s defense of denial and alibi was rejected as inherently weak, especially when juxtaposed with AAA’s positive identification and his own judicial admission before the barangay officials. His claim of coercion was unsupported by evidence. The Court modified the damages awarded, increasing civil indemnity, moral damages, and exemplary damages to P75,000.00 each, in line with prevailing jurisprudence. All monetary awards were subject to six percent (6%) interest per annum from the finality of the decision. The penalty of reclusion perpetua was upheld.