G.R. No. 235799 July 29, 2019
JASPER MONROY y MORA, Petitioner, vs. PEOPLE OF THE PHILIPPINES, Respondent.

FACTS

Petitioner Jasper Monroy was charged with Rape in relation to Republic Act No. 7610 (the Special Protection of Children Against Abuse, Exploitation and Discrimination Act). The prosecution alleged that on October 17, 2014, in Valenzuela City, the petitioner, who was drunk and wearing only his underwear, forcibly pulled the 14-year-old victim AAA onto his bed, removed her clothing, and inserted his penis into her vagina against her will. AAA tried to shout but was muffled. After the incident, distraught, she consumed dog medicine in a suicide attempt and was later hospitalized. She subsequently reported the rape to her sister and the police. A medico-legal examination confirmed blunt force penetrating trauma to her hymen.
In his defense, Monroy claimed that AAA had a crush on him and that he had rebuffed her advances. He alleged that her suicide attempt was due to this rejection and that the rape accusation was fabricated out of spite after he announced his plan to return to his family in the province. He presented a letter written by AAA which he claimed supported his theory of a scorned woman.

ISSUE

Whether the Court of Appeals correctly affirmed petitioner Jasper Monroy’s conviction for violation of Section 5(b), Article III of R.A. No. 7610 (child abuse through sexual intercourse).

RULING

Yes. The Supreme Court affirmed the conviction. The Court meticulously examined the evidence and found the testimony of the minor victim, AAA, to be credible, consistent, and corroborated by the medico-legal findings. Her account of the forcible sexual assault was detailed and unshaken. In contrast, the petitioner’s defense of denial and imputation of ill motive on the victim was weak and self-serving. The Court found his claim that a 14-year-old would falsely accuse him of a grave crime after a rejected crush to be implausible and contrary to human experience.
The legal logic centers on the proper classification of the crime. The Information alleged Rape under the Revised Penal Code (RPC) in relation to R.A. 7610. However, for a minor victim aged 14, the applicable law is specifically Section 5(b) of R.A. 7610, which penalizes sexual intercourse with a child subjected to other sexual abuse. The elements are: (1) the accused commits the act of sexual intercourse; and (2) the act is performed with a child exploited in prostitution or subjected to other sexual abuse. Here, the act of sexual intercourse was proven, and the victim, being a child below 18, is deemed “subjected to other sexual abuse” by the very fact of the unlawful sexual intercourse, regardless of whether force or intimidation was present. Thus, the petitioner was correctly convicted under this provision, not for statutory or qualified rape under the RPC. The penalties and damages awarded by the lower courts were sustained.