G.R. No. 239138 , February 17, 2021
People of the Philippines, Plaintiff-Appellee, vs. Joselito Salazar y Granada, Accused-Appellant.

FACTS

The accused-appellant, Joselito Salazar y Granada, was charged with the rape of AAA, a 15-year-old minor, on or about February 24, 2013, in Pasig City. The prosecution’s version, as testified by AAA, is that on February 23, 2013, Salazar invited her to meet her boyfriend. Instead, he forced her into his house, poked a metal object at her waist, closed the door, ordered her to lie down, and punched her abdomen when she resisted. He then removed her clothes, caressed her breast, licked her vagina, and repeatedly inserted his penis into her vagina. AAA did not shout for help despite a woman knocking on the door during the incident, out of fear due to Salazar’s strength and the presence of a pair of scissors. Afterward, Salazar took her to his cousin Becka’s house, where AAA disclosed the rape. She then reported the incident to her family, leading to Salazar’s arrest. A Medico-Legal Report confirmed recent blunt force trauma to her genitalia and a shallow healed hymenal laceration but found no external physical injuries and was negative for spermatozoa. The defense presented an alibi, with Salazar claiming he was cooking, then drinking with relatives at the time, and denial, supported by witnesses who placed him elsewhere. The Regional Trial Court convicted Salazar of rape and sentenced him to Reclusion Perpetua, ordering him to pay moral and exemplary damages. The Court of Appeals affirmed the conviction with modifications to the damages.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellant Joselito Salazar y Granada for the crime of rape.

RULING

The Supreme Court denied the appeal and affirmed the conviction. The Court held that all elements of rape under Article 266-A of the Revised Penal Code were proven beyond reasonable doubt: (1) Salazar had carnal knowledge of AAA; and (2) it was accomplished through force, threat, and intimidation. The Court emphasized that intimidation is subjective and addressed to the mind of the victim; thus, AAA’s failure to shout or escape does not negate rape, as people react differently to distressing situations. The force and intimidation were established by Salazar poking a metal object at her, punching her, and the threatening presence of scissors. The Medico-Legal Report, showing recent blunt force trauma, corroborated her testimony, while the absence of fresh lacerations or spermatozoa does not disprove rape, as these are not elements of the crime. The positive, straightforward, and categorical testimony of AAA, who had no motive to falsely accuse, prevailed over Salazar’s weak defense of denial and alibi, which was not physically impossible and was contradicted by his own witnesses. The Court modified the damages, awarding civil indemnity, moral damages, and exemplary damages of P75,000.00 each, with interest at 6% per annum until fully paid.