G.R. No. 230626, March 09, 2020
People of the Philippines, Appellee, v. Edward Sumayod y Osano and Eliseo Sumayod y Lagunzad, Accused-Appellant.

FACTS

The case involves the rape and sexual assault of the minor AAA, who was six years old at the time of the incidents. AAA was left in the care of her maternal grandmother, BBB, due to her parents’ circumstances. In December 2007, BBB temporarily left AAA with another daughter, who then left AAA with accused-appellant Eliseo Sumayod (her grandfather) and his common-law wife, Teresita. Accused-appellant Edward Sumayod (her uncle), then 17 years old, also resided with them.
On March 26, 2008, Edward dragged AAA into his bedroom, removed her clothing, and inserted his penis into her vagina, mouth, and anal orifice. On August 13, 2008, Eliseo entered the room where AAA was sleeping, laid on top of her, and inserted his penis into her vagina, mouth, and anal orifice. Both accused threatened AAA to prevent her from reporting the acts. In April 2009, Edward raped AAA again near a river in Leyte. In June 2009, AAA exhibited physical distress, and a medical examination revealed injuries to her genitalia, hymenal lacerations, and the presence of spermatozoa. On July 1, 2009, Edward raped AAA once more, after which she disclosed the abuses to BBB. AAA underwent sessions with a child psychiatrist, who confirmed sexual abuse.
Edward and Eliseo were charged with rape and rape by sexual assault. They pleaded not guilty. The Regional Trial Court convicted both accused. The Court of Appeals affirmed the convictions. The case was elevated to the Supreme Court via an ordinary appeal.

ISSUE

The core issue is whether the guilt of accused-appellants Edward Sumayod and Eliseo Sumayod for the crimes of rape and rape by sexual assault was proven beyond reasonable doubt.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the convictions with modifications to the awards of damages. The Court held that AAA’s testimony, given in a categorical, straightforward, and consistent manner, was credible and sufficient to establish the crimes. The Court emphasized that the testimony of a child victim, when credible, is sufficient for a conviction. The medical findings corroborated AAA’s account. The defenses of denial and alibi presented by the accused-appellants were weak and could not prevail over the positive identification and credible testimony of the victim. The qualifying circumstances of minority and relationship were duly proven.
The Court modified the damages awarded, increasing the amounts for civil indemnity, moral damages, and exemplary damages in accordance with prevailing jurisprudence, and imposed interest on all damages awarded at the legal rate of six percent per annum from the finality of the judgment until full payment.