GR 92169 70; (June, 1991) (Digest)
G.R. Nos. 92169-70; June 19, 1991
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ELEUTERIO RAPTUS y JERAY, accused-appellant.
FACTS
Accused-appellant Eleuterio Raptus was convicted by the Regional Trial Court of Caloocan City for two counts of rape committed against eleven-year-old Arlene Cabe. The first incident occurred on October 3, 1988, when appellant lured the victim by asking her to buy cigarettes, brought her to his house, threatened her, and then forcibly had carnal knowledge of her. He gave her P20.00 and threatened her not to report the assault. The second incident on November 4, 1988, followed a similar pattern, with appellant using the same pretext to bring the victim to an abandoned house where he again raped her, again giving her money and a threat afterward. The crimes were revealed in December 1988 when a neighbor informed the victim’s mother, leading to a confrontation and a subsequent medical examination which confirmed the victim’s non-virgin state.
ISSUE
Whether the trial court erred in convicting the accused-appellant of two counts of rape despite his claims casting reasonable doubt on the victim’s credibility and his denial of the accusations.
RULING
The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of the minor victim’s testimony as credible and convincing. It emphasized that the trial judge’s firsthand observation of witness demeanor is entitled to great respect. The Court rejected the appellant’s defense of denial and his implausible theory that the case was fabricated due to a personal grudge, noting it was inconceivable that a mother would subject her child to the scandal of a false rape charge. The legal logic centered on the elements of rape and the credibility of the child victim’s account. The Court explained that the victim’s failure to immediately shout or report the incidents did not undermine her credibility, as her reactions were dominated by fear due to the appellant’s threats. Furthermore, the Court clarified that for statutory rape, the victim’s consent is immaterial given her age of eleven years. The medico-legal findings, while not showing fresh trauma, corroborated her non-virgin state consistent with the recounted events. The appealed decision was affirmed with modification, increasing the civil indemnity to P30,000.00 for each count.