G.R. No. 227749 , September 22, 2020
People of the Philippines, Plaintiff-Appellee, vs. Ben Suwalat, Accused-Appellant.

FACTS

The accused-appellant, Ben Suwalat, was charged with two counts of rape against the minor victim, CCC, a fourteen-year-old mental retardate. The first incident allegedly occurred in August 2006 at the appellant’s house, where the victim was sleeping. She testified that she was awakened by pain, found the appellant on top of her, and that he forcibly had carnal knowledge with her. He threatened to kill her if she reported the incident. The second incident allegedly occurred on November 1, 2006, inside the victim’s own home. She stated that the appellant entered their house, mounted her while she was in bed, held her hands, and pressed a knife against her body while threatening her. After this second incident, she reported the rapes to her father, leading to a barangay and police report and a medico-legal examination which confirmed an old hymenal laceration.
The defense presented a denial and alibi. For the August incident, the appellant claimed he was in another location working. For the November incident, he alleged he was at home with his family. The Regional Trial Court found the accused guilty beyond reasonable doubt of two counts of rape and sentenced him to reclusion perpetua for each count. The Court of Appeals affirmed the conviction with modifications to the awarded damages.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of the accused-appellant for two counts of rape.

RULING

The Supreme Court denied the appeal and affirmed the conviction. The Court held that the victim’s categorical, consistent, and straightforward testimony, corroborated by the medico-legal findings, sufficiently established the fact of rape. The defense of denial and alibi cannot prevail over the positive identification by the victim. The Court emphasized that testimonies of child-victims of rape are given full weight and credit, as youth and immaturity are generally badges of truth. The victim’s mental disability did not impair her credibility; instead, her simple narration of the traumatic events lent credence to her account.
The Court found the elements of rape under Article 266-A of the Revised Penal Code present: the carnal knowledge was accomplished through force and intimidation, as demonstrated by the appellant’s use of a knife and threats to kill. The qualifying circumstance of the victim’s mental disability under Republic Act No. 7610 was also properly alleged and proven. The penalties of reclusion perpetua for each count were affirmed as proper. The Court also sustained the modified awards of civil indemnity, moral damages, and exemplary damages at P75,000.00 each per count, with interest, pursuant to prevailing jurisprudence.