G.R. No. 242512 . August 14, 2019.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. MARINO BAYA Y YBIOSA, ACCUSED-APPELLANT.

FACTS

Accused-appellant Marino Baya was charged with multiple counts of rape and acts of lasciviousness against three minors, AAA (7 years old), BBB (9 years old), and CCC (8 years old), allegedly committed in September 2006 in Muntinlupa City. The charges were filed under Article 336 of the Revised Penal Code in relation to Republic Act No. 7610 (RA 7610). The prosecution presented the sworn statements of the victims and the testimony of BBB and CCC. BBB testified that on September 26, 2006, Baya sexually assaulted her and she witnessed him do the same to AAA and CCC. CCC corroborated this, testifying to acts of lasciviousness committed against her. The defense presented alibi and denial.
The Regional Trial Court convicted Baya of two counts of rape and two counts of acts of lasciviousness. The Court of Appeals affirmed the convictions but modified the penalties and damages. Baya appealed to the Supreme Court, arguing the prosecution failed to prove his guilt beyond reasonable doubt and questioning the credibility of the child witnesses.

ISSUE

The core issue is whether the prosecution successfully proved the guilt of the accused-appellant for the crimes charged beyond reasonable doubt.

RULING

The Supreme Court partially granted the appeal. It acquitted Baya in Criminal Case Nos. 06-884 and 07-286 (acts of lasciviousness against AAA) and remanded Criminal Case Nos. 07-281 to 07-284 and 07-288 for proper arraignment. However, it affirmed his convictions in Criminal Case No. 07-285 (rape of BBB) and Criminal Case No. 07-287 (acts of lasciviousness against CCC).
The legal logic for the affirmations rests on the credible and categorical testimonies of the child victims, BBB and CCC. The Court emphasized that testimonies of child victims are given full weight and credit, as youth and immaturity generally make them incapable of fabrication. BBB’s detailed account of the rape and CCC’s consistent narration of the lascivious acts were found to be straightforward and unshaken by cross-examination. The defense of alibi and denial cannot prevail over these positive identifications. For the rape of BBB, the element of carnal knowledge with a child below twelve was established, making it statutory rape. For the acts against CCC, the lewd acts described constituted lascivious conduct under the law. The Court imposed the penalty of reclusion perpetua for the rape and reclusion temporal for the acts of lasciviousness, with corresponding damages. The acquittals for charges involving AAA were due to the prosecution’s failure to present her as a witness, rendering her sworn statement inadmissible as hearsay.