G.R. No. 244047, December 10, 2019
People of the Philippines, Plaintiff-Appellee, vs. XXX, Accused-Appellant.

FACTS

Accused-appellant XXX was charged with qualified statutory rape for allegedly having sexual intercourse with AAA, a five-year-old minor, on the evening of January 2, 2013, and early morning of January 3, 2013, in San Fabian, Pangasinan. He was the live-in partner of AAA’s mother. During pre-trial, the parties stipulated on the identity of the parties, the victim’s minority (born June 6, 2007), the fact of reporting the incident to the police, and the physical existence of a medico-legal report. The prosecution presented AAA, her mother, and PO2 Irene Robosa. AAA testified that accused-appellant, whom she called “uncle,” placed his penis inside her vagina, which caused her pain the next day. Her mother testified that she discovered the incident when AAA complained of vaginal pain; upon inspection, she found AAA’s vagina “very red,” and accused-appellant allegedly admitted to “playing with” or “fingering” AAA’s vagina. PO2 Robosa testified about the police report and accused-appellant’s alleged admission. The defense presented only accused-appellant, who denied the rape and claimed the accusation was an extortion attempt motivated by his pending labor case monetary claim.

ISSUE

Whether or not accused-appellant’s conviction for qualified statutory rape was proper.

RULING

Yes, the conviction was proper. The Supreme Court affirmed the Court of Appeals decision, which upheld the Regional Trial Court’s finding of guilt. The elements of qualified statutory rape were proven beyond reasonable doubt: (1) the victim was under 12 years old (five years old at the time), and (2) the accused had carnal knowledge of her. The qualifying circumstance that the offender is the common-law spouse of the victim’s parent was also established. The Court found AAA’s categorical testimony credible, despite her tender age, and noted that testimonies of young rape victims are given full credit. The alleged inconsistencies in her testimony (e.g., not feeling anything during the act but feeling pain later, and not seeing the penis as she was asleep) were deemed insufficient to overturn the credibility assessments of the trial and appellate courts. The denial of the accused-appellant, unsupported by strong evidence, could not overcome the positive identification and testimony of the victim, which was corroborated by her mother’s testimony and the medico-legal findings. The penalty of reclusion perpetua without eligibility for parole was correctly imposed. The awards of damages were modified to P100,000.00 each for civil indemnity, moral damages, and exemplary damages, with 6% per annum interest from finality until full payment.