G.R. No. 240217 , June 23, 2020
People of the Philippines, Plaintiff-Appellee, vs. Reggie Briones y Duran, Accused-Appellant.

FACTS

The accused-appellant, Reggie Briones y Duran, was charged with the rape of “FFF,” a 12-year-old child, on or about July 19, 2006, through force, intimidation, and abuse of confidence. The prosecution established that on that date, while FFF was alone in their house, Briones, a neighbor whom she considered her “kuya,” arrived, asked to increase the television volume, closed and locked the door, embraced her, pushed her against the door, forcibly removed her underpants, and had carnal knowledge with her despite her pleas and attempts to push him away. He threatened to kill her and her family if she told anyone. The sexual encounters were repeated eight more times. FFF’s parents discovered the ordeal in December 2006 when she missed her menstrual period. A medical examination on January 1, 2007, confirmed her pregnancy and revealed completely healed old hymenal lacerations. The defense, however, claimed that Briones and FFF were sweethearts and that their sexual relations were consensual. Briones presented love letters allegedly written by FFF and the testimony of his cousin, Mary Ann Briones, to corroborate his claim of a romantic relationship.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of the accused-appellant for the crime of rape under Article 266-A, paragraph (1) of the Revised Penal Code.

RULING

The Supreme Court denied the appeal and affirmed the modified decision of the Court of Appeals. The Court held that the prosecution proved beyond reasonable doubt all the elements of rape through force, threat, or intimidation under Article 266-A(1)(a) of the Revised Penal Code. The credible and convincing testimony of the victim, FFF, detailing how Briones used force and intimidation to have carnal knowledge of her, was given full weight and credence. The Court rejected the “sweetheart defense,” finding the love letters insufficient to prove consent, especially given the victim’s age, the force employed, and the subsequent threats. The Court also clarified that any inconsistency in the trial court’s decision regarding the applicable law (between the Revised Penal Code and Republic Act No. 7610 ) was inconsequential, as the Information clearly alleged rape by means of force and intimidation, and the evidence supported a conviction under the Revised Penal Code. The Court sustained the penalties and awards of damages as modified by the Court of Appeals: reclusion perpetua, civil indemnity of Php75,000.00, moral damages of Php75,000.00, exemplary damages of Php75,000.00, all with interest at 6% per annum from the finality of judgment until fully paid.