G.R. No. L-61165 June 24, 1985
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FRED PELIAS JONES, defendant-appellant.

FACTS

The defendant-appellant, Fred Pelias Jones, was convicted by the Court of First Instance of Cebu of the crime of rape against his nine-year-old daughter, Mary Jane Pelias Jones, and sentenced to reclusion perpetua. The prosecution established that on the evening of October 4, 1981, in their residence in Cebu City, the appellant sent his younger daughter out of the house. He then called Mary Jane into the toilet, pulled her inside, removed her panties, and had carnal knowledge of her against her will, threatening to kill her if she revealed the act. The crime was discovered days later when the child’s mother, Anita Pelias Jones, pieced together information from her daughters and confronted Mary Jane, who divulged the rape.
Anita immediately brought Mary Jane for a medical examination at Southern Islands Hospital. Dr. Cesar V. Semilla’s medico-legal certificate confirmed sexual intercourse, noting a third-degree hymenal laceration. When confronted, the appellant initially denied the act but later made statements to his wife suggesting the incident should be forgotten. While incarcerated, he wrote letters pleading for forgiveness and urging his wife not to testify, which he later claimed pertained to marital infidelity, not the rape.

ISSUE

The core issue is whether the prosecution proved beyond reasonable doubt the appellant’s guilt for the crime of rape against his minor daughter.

RULING

The Supreme Court affirmed the conviction. The legal logic rests on two pivotal points. First, under Article 335 of the Revised Penal Code, as amended, carnal knowledge of a girl under twelve years of age is always statutory rape. The gravamen of the offense is the child’s age, rendering consent, force, or intimidation irrelevant. Mary Jane was nine years old at the time, thus the act constituted rape by definition.
Second, the evidence conclusively established the appellant’s guilt. The victim’s testimony, given in a straightforward and childish manner, was credible and consistent. It was corroborated by the medical findings of a hymenal laceration, which provided physical evidence of sexual intercourse. The appellant’s letters from jail, while he argued they referred to infidelity, were interpreted by the Court as implicit admissions intended to dissuade prosecution. The letters contained pleas for forgiveness and direct requests for his wife not to attend the trial, which the Court found incompatible with a mere marital dispute and indicative of guilt for the grave charge. The trial court’s assessment of witness credibility was upheld. The penalty of reclusion perpetua was affirmed, with the added modification for the appellant to indemnify the victim in the amount of P20,000.00.