G.R. No. 238622 , December 07, 2020
People of the Philippines, Plaintiff-Appellee, vs. Randy Licaros y Flores, Accused-Appellant.

FACTS

The prosecution alleged that on April 9, 2009, the victim AAA, after a drinking session at her aunt’s house, felt dizzy and was assisted to an upstairs bedroom by her cousin, accused-appellant Randy Licaros. Once there, Licaros moved on top of AAA, kissed her, and proceeded to pull down her shorts and underwear despite her resistance of kicking and pushing. He pinned her hands to her chest, removed his own garments, and succeeded in having carnal knowledge with her. AAA did not immediately report the incident out of fear but later confided in her stepmother, leading to a medical examination. The medico-legal report confirmed healed lacerations consistent with previous penetrating trauma.
The defense presented a denial, claiming Licaros merely assisted AAA upstairs with another cousin around 7:00 PM and then returned downstairs to continue drinking. His sister was allegedly present upstairs and saw AAA being assisted. The defense argued that the victim’s testimony was improbable and that the element of force or intimidation was not proven.

ISSUE

The core issues were: (1) whether the lower courts erred in giving full credence to AAA’s testimony, and (2) whether the prosecution proved the essential element of force or intimidation in the rape.

RULING

The Supreme Court affirmed the conviction. On the first issue, the Court upheld the assessment of the trial court, which found AAA’s testimony to be clear, candid, and straightforward. Her detailed account of the sexual assault and her immediate resistance were deemed credible. The Court emphasized that testimonies of rape victims, especially when consistent with medical findings, are accorded great weight. The medico-legal report, showing healed lacerations, corroborated her claim of previous penetration, rendering the defense of bare denial weak and unavailing.
On the second issue, the Court ruled that force was sufficiently established. The act of pinning AAA’s hands to her chest while removing her clothing and overcoming her physical resistance constituted the force necessary to consummate the rape. The law does not require the highest degree of force, only that the force used is sufficient to subdue the victim’s will. AAA’s attempt to shout, which produced no voice due to shock and fear, further illustrated the coercive nature of the attack. Thus, all elements of rape under Article 266-A were proven beyond reasonable doubt. The Court sustained the penalty of reclusion perpetua and the awarded damages.