G.R. No. 246194 , November 04, 2020
People of the Philippines, Plaintiff-Appellee, vs. XXX, Accused-Appellant.

FACTS

The accused-appellant was charged with the rape of AAA, an eight-year-old minor, on June 10, 2013. The prosecution evidence established that the accused, a grand uncle of the victim, lured her to his house under the pretext of buying candy. Upon her return, he forcibly laid her down, removed their clothing, and had carnal knowledge of her. The act was witnessed by CCC, the victim’s uncle, who saw the accused standing to put on his underwear while the victim was on the floor putting on her panty. CCC immediately reported the incident to the victim’s mother. A medical examination conducted the following day confirmed hymenal lacerations at the 3, 6, and 9 o’clock positions.
The defense presented a denial and alibi. The accused-appellant claimed he was at a drinking session and later at home taking a bath, asserting that the accusation was fabricated following a confrontation and a physical altercation with CCC and others. He suggested the charge was motivated by ill will. Both the Regional Trial Court and the Court of Appeals found him guilty, with the CA modifying the award of damages. The accused appealed to the Supreme Court.

ISSUE

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

RULING

The Supreme Court denied the appeal and affirmed the conviction. The Court emphasized that the credibility of the victim’s testimony, given her tender age, is accorded great weight. Her categorical and consistent narration of the sexual assault, corroborated by the eyewitness account of CCC and the medical findings of fresh hymenal lacerations, constituted proof beyond reasonable doubt. The defense of denial and alibi cannot prevail over the positive identification by the victim and the witness.
The legal logic rests on the principle that the testimonies of child-victims of rape are given full credence, as a young girl would not concoct a story of defloration and undergo the ordeal of a public trial if not motivated by a desire to seek justice. The medical evidence provided strong physical corroboration. The alleged ill motive of the witnesses was insufficient to discredit the clear and convincing evidence of the prosecution. The crime committed is statutory rape under Article 266-A(1)(d) of the Revised Penal Code, as the victim was under twelve years of age, making her consent irrelevant. The Court affirmed the penalties and modified the awarded damages in accordance with prevailing jurisprudence.