People v. Suedad
REITERATIONFacts
The Antecedents: The accused was charged in four informations for the crime charged against his daughter AAA, born on 1997-07-05. The informations allege multiple occasions of the crime charged occurring on 2008-10-20, during the last week of October 2008, 2008-11-26 and 2009-03-20. At the pre-trial conference it was stipulated that AAA is the natural/biological daughter of the accused. The prosecution presented AAA, her mother BBB, maternal grandmother CCC, maternal aunt DDD, and Dr. Raul Manansala, Municipal Health Officer, who prepared a medico-legal report noting partial healed lacerations and hymenal admit of one finger with ease. Procedural History: A complaint was filed on 2009-04-21. On 2011-06-09, the Regional Trial Court (RTC) found the accused guilty beyond reasonable doubt of three counts of the crime charged (Criminal Cases Nos. 115, 117 and 118) and acquitted him in Criminal Case No. 116. The Court of Appeals, in CA-G.R. CR.-H.C. No. 00955-MIN dated 2013-09-06, affirmed the RTC decision with modification, including the imposition of reclusion perpetua without eligibility for parole and awards of civil indemnity, moral and exemplary damages. The accused appealed to the Supreme Court. The Petition: The accused appealed the Court of Appeals decision contending, inter alia, on the insufficiency of evidence and alleged ill motives behind the filing of charges. The Office of the Solicitor General (OSG) and the accused were given opportunity to file supplemental briefs but neither did.
Issue(s)
Whether the evidence is sufficient to convict the accused of the crime charged in Criminal Cases Nos. 115, 117 and 118. Whether the RTC erred in acquitting the accused in Criminal Case No. 116. Whether the trial and appellate courts properly assessed the credibility of the victim and the weight of the medical findings. Whether the penalty and damages imposed by the appellate court require modification in light of prevailing law and jurisprudence. Whether the passage of Republic Act No. 9346 affects the penalty applicable to the crime charged.
Ruling
The Supreme Court affirmed with modification the Court of Appeals decision. The accused Renato B. Suedad is found guilty beyond reasonable doubt of three counts of the crime charged in Criminal Cases Nos. 115, 117 and 118 and is sentenced to suffer reclusion perpetua for each count. The award of damages was increased: for each count the accused is ordered to pay P100,000.00 as civil indemnity, P100,000.00 as moral damages and P100,000.00 as exemplary damages, with interest at 6% per annum from finality until fully paid. No pronouncement as to costs. Criminal Case No. 116 had been acquitted at trial and that disposition stands as reflected in the procedural history.
Ratio Decidendi
On Whether the evidence is sufficient to convict in Cases Nos. 115, 117 and 118: The Court held that the prosecution sufficiently proved the accused’s guilt beyond reasonable doubt. The ruling emphasized the settled principle that when the offended party is under twelve years of age, sexual congress is always the crime charged and the consent of the victim is immaterial, citing People v. Sabal, Jr. The Court found AAA’s testimony to be credible, spontaneous and categorical, and accorded it full weight in accordance with People v. Pascua and People v. Aguilar. The medical findings in the medico-legal report, showing hymenal lacerations and admit of one finger, corroborated the victim’s testimony and satisfied the elements of carnal knowledge as explained in People v. Perez. Given the concurrence of credible testimonial evidence and medical corroboration, the Court concluded that the elements of the crime charged were established beyond reasonable doubt. On Whether the RTC erred in acquitting the accused in Criminal Case No. 116: The Court did not disturb the acquittal in Criminal Case No. 116 as rendered by the trial court. The appellate history shows that the RTC found insufficient clear and convincing evidence for that particular information and the Court found no compelling reason to reverse that factual determination absent a clear showing that the trial court overlooked or misapplied facts. Applying the same standards of review enunciated in People v. Paculba, the Court respected the trial court’s assessment of the evidence in that count given its superior position to observe witnesses. On Whether the trial and appellate courts properly assessed credibility and medical findings: The Court reiterated that the trial court’s factual findings on credibility are entitled to great weight and will not be disturbed on appeal absent clear error, citing People v. Paculba. The Court explained that AAA’s testimony was consistent with human experience and normal behavior, and that any delay in reporting could be explained by fear and threats, relying on People v. Vitero and People v. Simoro. It further reasoned that medical evidence of hymenal lacerations provides objective corroboration of sexual penetration and therefore strengthens the victim’s testimony as held in People v. Perez. The cumulative effect of credible testimony and medical corroboration justified the courts’ conclusions. On Whether the penalty and damages require modification: The Court affirmed the penalty as reclusion perpetua for each count in light of Republic Act No. 9346 which abolished the death penalty but left qualified rape as a grave offense punishable by reclusion perpetua; therefore the appellate court’s reduction of penalty from death to reclusion perpetua was proper. However, the Court modified the damages and increased civil indemnity, moral and exemplary damages to P100,000.00 each per count pursuant to prevailing jurisprudence such as People v. Gambao and People v. Vitero, and ordered interest at the legal rate until fully paid. On the effect of Republic Act No. 9346: The Court explained that Republic Act No. 9346 removes the death penalty as a possible punishment, but does not declassify the crime charged as heinous for purposes of penalty determination; thus the appropriate penalty is reclusion perpetua without eligibility for death penalty, consistent with the legislative change and prior jurisprudence.
Main Doctrine
Where the offended party is under twelve years of age, sexual intercourse is always rape and the victim’s consent is immaterial; a conviction may be based solely on the credible, natural, convincing and consistent testimony of the victim when corroborated by medical findings such as hymenal lacerations.