G.R. No. 232157, January 08, 2020
People of the Philippines, Plaintiff-Appellee, v. Noel Dolandolan, Accused-Appellant.

FACTS

An Information was filed accusing Noel Dolandolan of the crime of Rape, committed on or about February 10, 1995, in Zambales. The information alleged that by means of force and intimidation and with the use of a sharp pointed instrument, he forcibly took AAA, a 15-year-old minor, deprived her of liberty, and had carnal knowledge of her against her will. After arrest and release on recognizance based on a claim of minority, accused-appellant was later re-arrested in 2012 following a warrant issued after he could not be produced. He pleaded not guilty upon arraignment.
The prosecution presented AAA and Dr. Crizalda Abrigo-Peralta. AAA testified that on February 10, 1995, while at a peryahan, accused-appellant, whom she did not know, introduced himself, forced her to walk with him for over an hour to a creek in another barangay while pointing a knife-like object, and then raped her. She cried from pain. Her parents found her, and she was taken to the police and later to a hospital. In her Sinumpaang Salaysay, she gave a more detailed account, stating accused-appellant pointed a ballpen-like knife, dragged her, made her ride a tricycle, and walked her to a place beside a river where he raped her, threatening to kill her if she shouted. During cross-examination, she gave some variations, stating he kissed her at the peryahan, used a stick or ballpen-like weapon, and that the rape occurred in a dark, vacant lot, not a creek. Dr. Abrigo-Peralta testified that her medico-legal examination of AAA revealed redness, swelling, and blood clots in the vaginal canal indicative of trauma and penetration, though the hymen was intact, which she explained could be due to elasticity given AAA’s youth.
The defense presented only accused-appellant, who testified that in 1995, he was 18 and working at the peryahan. He claimed he courted AAA for about a week before the incident, and on February 10, she agreed to go with him to his house to meet his parents. They arrived late, his father scolded him, and they all stayed awake outside the house the entire night with his father watching. The next morning, they went to a nearby falls to bathe, after which people arrived and took him to the police station where he learned of the rape charge. He denied any sexual intercourse.
The Regional Trial Court (RTC) found accused-appellant guilty beyond reasonable doubt of Rape, sentencing him to Reclusion Perpetua without eligibility for parole and ordering him to pay damages. The RTC held that while kidnapping was not established, rape through force and intimidation was proven, noting that inconsistencies in AAA’s testimony did not negate the essential fact of rape, which was supported by medical findings. The RTC also found that accused-appellant was about 23 years old at the time of the crime based on a corrected birth certification. The Court of Appeals (CA) affirmed the RTC decision but increased the exemplary damages.

ISSUE

Whether the Court of Appeals erred in affirming accused-appellant’s conviction for the crime of Rape.

RULING

The Supreme Court denied the appeal and affirmed the CA decision with modifications to the awards of damages. The Court held that all the elements of rape under Article 335 of the Revised Penal Code were proven: (1) accused-appellant had carnal knowledge of AAA; (2) it was done through force or intimidation; and (3) AAA was under 18 years of age at the time. The Court found AAA’s testimony credible and consistent on the central fact of sexual violation. The minor inconsistencies between her sworn statement and court testimony regarding ancillary details (e.g., the exact location, the sequence of events) were not fatal and did not undermine her core assertion. The Court emphasized that in rape cases, the victim’s testimony, if credible, is sufficient to sustain a conviction. The medical findings, showing trauma and blood clots in the vaginal canal, corroborated her claim of penetration. The Court rejected accused-appellant’s defense of sweetheart theory as a mere denial, which could not prevail over AAA’s positive identification and detailed account. The Court also upheld the finding that accused-appellant employed intimidation, given the weapon and threats, which instilled fear in AAA, a young and slight girl, compelling her submission. The penalty of Reclusion Perpetua without eligibility for parole was affirmed. The Court awarded civil indemnity, moral damages, and exemplary damages, setting each at Php75,000.00, and imposed interest at 6% per annum on all damages from finality of judgment until full payment.