G.R. No. 229209, February 12, 2020
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. ZZZ, ACCUSED-APPELLANT.
FACTS
Accused-appellant ZZZ was charged with the rape of his 15-year-old granddaughter, AAA, sometime in December 2010 in San Fernando, Romblon. The Information alleged the act was committed through force, threat, and intimidation, taking advantage of AAA’s minority and lack of education. AAA testified that she lived with ZZZ. On the day of the incident, after weeding grass, ZZZ placed himself on top of her, kissed her lips and genitals, undressed her, turned her sideways, and inserted his penis into her vagina. Afterward, she left and slept in the forest. The next day, when she tried to return home, ZZZ allegedly attacked her with a bolo, but she parried the attacks and ran to seek help from Barangay Captain Manuel Lotec. AAA stated such incidents happened often. Barangay Captain Lotec testified that on January 9, 2011, AAA reported being chased and raped by ZZZ, and she appeared pale and trembling. Social worker Rosa Ravalo assisted AAA in executing her affidavit and accompanied her to a medical exam. Dr. Lolinie Celestial B. Montojo examined AAA, and the parties stipulated to the medical certificate, which indicated old, healed hymenal lacerations. The defense presented only ZZZ, who denied the accusation, claiming his advanced age rendered him incapable of having an erection. The Regional Trial Court found ZZZ guilty beyond reasonable doubt of rape and sentenced him to reclusion perpetua, ordering him to pay P75,000 as indemnity and P50,000 as moral damages. The Court of Appeals affirmed the conviction but modified the damages, reducing civil indemnity to P50,000 and adding P30,000 in exemplary damages. ZZZ appealed to the Supreme Court.
ISSUE
Whether the prosecution proved beyond reasonable doubt the guilt of accused-appellant ZZZ for the crime of rape.
RULING
Yes. The Supreme Court dismissed the appeal and affirmed the conviction with modifications to the damages. The Court held that the trial court’s assessment of witness credibility, especially when affirmed by the Court of Appeals, is entitled to great weight and respect. AAA’s testimony was found to be credible, natural, and consistent. The Court emphasized that in rape cases, conviction can be based solely on the victim’s testimony if it is credible and convincing, and courts must avoid outdated gender stereotypes in assessing a victim’s behavior. AAA’s positive identification of ZZZ as her rapist prevailed over his denial and unsubstantiated claim of impotence. The medico-legal finding of old, healed hymenal lacerations constituted compelling physical evidence of defloration, corroborating AAA’s account. The testimonies of Barangay Captain Lotec and Social Worker Ravalo further bolstered AAA’s credibility. The Court modified the awarded damages in line with prevailing jurisprudence, increasing them to P75,000 each for civil indemnity, moral damages, and exemplary damages, all with legal interest at 6% per annum from the finality of the decision until full payment.
