GR 247007; (March, 2021) (Digest)
G.R. No. 247007 , March 18, 2021
People of the Philippines, Plaintiff-Appellee, vs. AAA, Accused-Appellant.
FACTS
Accused-appellant AAA was charged with Rape under Article 266-A, paragraph 1(d) of the Revised Penal Code for an incident on August 23, 2007, against the minor victim BBB, who was seven years old. The prosecution’s version, based on the testimonies of BBB, her siblings, and her father, established that AAA, who frequently stayed at their house, carried the sleeping BBB to a nearby banana plantation on the night in question. There, he removed her pants and panty, touched her vagina, inserted his penis multiple times causing her pain, covered her mouth when she cried, and afterward swiped his penis on her face. BBB was able to identify AAA by the light from a neighbor’s house and by his familiar voice. She reported the incident to her father the next day. Medical examination revealed recent hymenal lacerations consistent with sexual abuse. The defense, comprising AAA and his relatives, denied the accusation. AAA claimed he was asleep in the house the entire night and suggested the charge was fabricated due to a grudge his father had against BBB’s father over a reported illegal logging incident.
ISSUE
Whether the Court of Appeals correctly affirmed the conviction of accused-appellant AAA for the crime of Rape.
RULING
The Supreme Court affirmed the conviction with modification. It found the testimony of the child-victim BBB to be credible, consistent, and corroborated by medical evidence. The Court rejected the defense of denial and alibi, noting they are weak defenses that cannot prevail over the positive identification by the victim. The alleged motive for fabrication was deemed insufficient to overturn the conviction. The Court modified the penalty and damages. AAA was found guilty beyond reasonable doubt of Simple Rape by Sexual Intercourse under Article 266-A, paragraph 1(a) of the Revised Penal Code, as amended. He was sentenced to suffer the penalty of Reclusion Perpetua and ordered to pay BBB the amounts of P75,000.00 as civil indemnity, P75,000.00 as moral damages, and P75,000.00 as exemplary damages, all with interest at 6% per annum from the finality of the decision until fully paid.