G.R. No. 257276 . February 28, 2022.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. XXX, ACCUSED-APPELLANT.

FACTS

Accused-appellant XXX was charged with Qualified Rape for allegedly having sexual intercourse with his niece, AAA, a seven-year-old minor, on or about August 8, 2009. The prosecution presented AAA, her mother BBB, and medico-legal reports. AAA testified that accused-appellant, her uncle, summoned her to his room, undressed her, kissed her, mounted her, and inserted his penis into her vagina, causing pain. He then ordered her to perform oral sex on him under threat of death. BBB testified that she witnessed, through a window, accused-appellant kissing AAA and AAA holding his penis. BBB confronted AAA, who reported the abuse, leading to a police report and medical examination. The medical certificate showed an abrasion on the labia majora and an old healed hymenal laceration. The defense presented accused-appellant’s denial, claiming he was asleep and alleging the case might be due to a land dispute. The Regional Trial Court (RTC) convicted accused-appellant of Qualified Rape, sentencing him to reclusion perpetua without parole and awarding damages. The Court of Appeals (CA) modified the conviction to Statutory Rape, affirming the penalty of reclusion perpetua but adjusting the damages, finding the allegation of relationship in the Information insufficient for qualification. Accused-appellant appealed.

ISSUE

Whether the Court of Appeals erred in affirming accused-appellant’s conviction for Statutory Rape.

RULING

No, the Court of Appeals did not err. The Supreme Court dismissed the appeal and affirmed the CA decision with modifications to the awarded damages. The Court held that the prosecution sufficiently established all elements of Statutory Rape: (1) AAA was under 12 years old at the time of the incident, as proven by her birth certificate; and (2) accused-appellant had carnal knowledge of AAA, as detailed in her clear, candid, and consistent testimony, which was corroborated by her mother’s testimony and the medico-legal findings. The Court emphasized that the trial court’s assessment of witness credibility is entitled to great weight, especially when affirmed by the CA, and found no reason to overturn these findings. The Court agreed with the CA that the crime was Statutory, not Qualified Rape, as the Information did not sufficiently allege the qualifying circumstance of relationship under prevailing jurisprudence. The penalty of reclusion perpetua was affirmed. Following current jurisprudence, the Court modified the damages, awarding AAA P100,000.00 as civil indemnity, P100,000.00 as moral damages, and P100,000.00 as exemplary damages, all with 6% per annum interest from finality of judgment until full payment.