G.R. No. 84310 ; May 29, 1991
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EDGAR CASTILLO, accused-appellant.

FACTS

Accused-appellant Edgar Castillo was charged with the rape of five-year-old Melba Luya. The prosecution’s evidence established that on February 15, 1986, the victim’s mother, Miguela Luya, discovered her daughter naked and standing beside Castillo, who was in his briefs, inside their barn. When confronted, Castillo fled. The child was medically examined, revealing a completely lacerated hymen with slight fresh bleeding, though no seminal fluid was found. During trial, Melba testified that after Castillo undressed her, he made her lie on top of him. She stated that while he made a push-and-pull movement, she felt his private part touch her vagina, causing her pain.
The defense consisted of Castillo’s denial, alleging the charge was fabricated by the victim’s parents to avoid paying his salary. He argued the acts proven constituted only acts of lasciviousness, not rape, emphasizing the victim’s testimony that she did not see his organ nor feel it penetrate her vagina fully.

ISSUE

Whether the acts proven constitute the crime of rape, specifically if there was sufficient “carnal knowledge” despite the victim’s testimony indicating only contact and not full penetration.

RULING

The Supreme Court affirmed the conviction. The legal logic centers on the definition of “carnal knowledge” in rape. The Court clarified that for rape to be consummated, full or complete penetration of the vagina is not required. What is essential is proof of the introduction, however slight, of the male organ into the labia of the female pudendum. The victim’s testimony that she felt the appellant’s private part touch her vagina, coupled with the medical finding of a freshly lacerated hymen, sufficiently establishes this essential element.
The Court rejected the appellant’s argument that inconsistencies in the child-victim’s testimony and her seemingly normal behavior after the incident negated rape. It emphasized that the testimony of a child of tender years cannot be expected to be flawless. The medical evidence corroborated her account of contact causing pain and injury. The defense of denial cannot prevail over the victim’s positive identification and credible narration. Consequently, the trial court correctly found the appellant guilty of rape under Article 335 of the Revised Penal Code. The penalty of reclusion perpetua was affirmed, with the modification that the appellant must pay civil indemnity of P40,000.00 to the victim.