G.R. No. 229100 November 20, 2017
People of the Philippines, Plaintiff-appellee vs. Romeo Agoncillo y Visto, Accused-appellant

FACTS

Accused-appellant Romeo Agoncillo was charged with three counts of rape and one count of acts of lasciviousness against his niece, AAA, and a separate count of rape against another minor, CCC. The prosecution evidence established that AAA was raped on three separate occasions in 2001, 2002, and 2003, when she was between nine and eleven years old. AAA testified that Agoncillo used a knife to threaten her into submission during each assault. Her mother reported the incidents in 2004, and a medico-legal examination revealed healed hymenal lacerations consistent with sexual intercourse. The defense consisted solely of Agoncillo’s denial and alibi, claiming he was working in Alabang from 2001 to 2004 and could not have committed the crimes in Pangasinan.
The Regional Trial Court convicted Agoncillo of three counts of statutory rape against AAA but acquitted him of the rape charge involving CCC (who did not testify) and the acts of lasciviousness charge. The Court of Appeals affirmed the RTC’s decision. Agoncillo appealed to the Supreme Court, arguing that AAA’s testimony was inconsistent and that his alibi should prevail.

ISSUE

The core issue is whether the prosecution proved Agoncillo’s guilt for the three counts of statutory rape beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The Court emphasized that in cases of statutory rape, where the victim is below twelve years of age, the only elements required are: 1) sexual intercourse with a woman, and 2) that she is under twelve years of age. Force, intimidation, or consent become immaterial. AAA’s positive identification of Agoncillo as her assailant, coupled with her consistent testimony on material points, was given full credence. The Court found her account of the repeated assaults, including the use of a knife and threats, to be straightforward and credible. The medico-legal findings of healed hymenal lacerations corroborated her claim of prior sexual intercourse.
The Court rejected Agoncillo’s defense of alibi and denial. Alibi is inherently weak and must be supported by clear and convincing evidence of the physical impossibility of the accused being at the crime scene. Agoncillo failed to substantiate his claim of working in Alabang during the entire period from 2001 to 2004. His bare denial could not overcome the positive identification and the strong evidence presented by the prosecution. The awards of civil indemnity, moral damages, and exemplary damages for each count of rape were sustained, with interest.