GR 231984; (July, 2020) (Digest)
G.R. No. 231984 , July 06, 2020
People of the Philippines, Plaintiff-Appellee, vs. Leo Ibañez y Morales, Accused-Appellant.
FACTS
Accused-appellant Leo Ibañez y Morales was charged with four counts of qualified rape committed against his niece, AAA, a minor, in March, April 12, April 25, and May 11, 2003. The Informations alleged that the acts were committed through force, threat, and intimidation with the use of a knife, taking advantage of moral ascendancy, with the qualifying circumstances of relationship and minority. During trial, AAA testified that on each occasion, Ibañez entered her house when she was alone, pointed a knife at her, and forcibly had sexual intercourse with her. The medical examination revealed old hymenal lacerations consistent with penetration by a blunt object. Ibañez denied the accusations, claiming he was working elsewhere due to a land dispute with AAA’s father, and asserted that AAA’s testimony was inconsistent and improbable. The Regional Trial Court convicted Ibañez of four counts of qualified rape. The Court of Appeals affirmed the conviction but modified the damages awarded.
ISSUE
Whether the Court of Appeals erred in convicting accused-appellant Leo Ibañez y Morales for four counts of qualified rape.
RULING
The Supreme Court affirmed the conviction. The Court held that the prosecution proved Ibañez’s guilt beyond reasonable doubt. AAA’s testimony was direct, positive, and categorical, and minor inconsistencies did not affect her credibility. The medical findings corroborated her account. The Court emphasized that the absence of physical injuries does not negate rape, as it is not an element of the crime, and that a victim’s reaction to sexual assault varies; failure to shout or escape immediately does not indicate consent. Ibañez’s defense of denial and alibi, uncorroborated by evidence, could not prevail over AAA’s credible testimony. The Court sustained the penalties of reclusion perpetua without eligibility for parole for each count and, following prevailing jurisprudence, awarded civil indemnity, moral damages, and exemplary damages of P100,000.00 each per count, with legal interest at 6% per annum from finality until full payment.