People v. XXX
REITERATIONFacts
The Antecedents: The accused-appellant was charged with Rape under Articles 266-A(1)(d) and 266-B of the Revised Penal Code (RPC), as amended by Republic Act (RA) No. 8363, in relation to RA 7610 and RA 8369. The Information alleged that on June 10, 2013, the accused-appellant, with lewd design, by the use of force or intimidation, willfully, unlawfully, and feloniously had carnal knowledge of the private complainant, AAA, a minor under twelve (12) years old, against her will and consent. The private complainant was eight years old at the time of the incident. The prosecution presented evidence that the accused-appellant called the private complainant to his house on her birthday, instructed her to buy candy, and upon her return, forcibly laid her down, removed their clothes, and inserted his penis into her vagina. A witness, CCC, allegedly saw the accused-appellant standing up and putting his underwear back on while the private complainant was on the floor putting on her panty. The private complainant reported the incident to her mother, leading to a confrontation with the accused-appellant and a report to the Barangay. The private complainant was medically examined and found to have hymenal lacerations. The accused-appellant denied the allegations, claiming he was engaged in a drinking spree and that the private complainant volunteered to buy candy. He alleged that CCC and DDD mauled him. Procedural History: The Regional Trial Court (RTC) of Aparri, Cagayan, Branch 9, found the accused-appellant guilty beyond reasonable doubt of Rape and sentenced him to suffer the penalty of reclusion perpetua, with civil indemnity and moral damages. The Court of Appeals (CA) affirmed the RTC decision with modification, increasing the civil indemnity and moral damages and adding exemplary damages. The accused-appellant appealed to the Supreme Court. The Petition: The accused-appellant challenged the RTC's conviction, questioning the credibility of prosecution witnesses, the lack of conclusive finding of rape, and the failure to consider his defense of denial. He argued that the private complainant failed to offer resistance, did not report the incident immediately, and that hymenal lacerations can have other causes. He also alleged ill motive on the part of witness CCC.
Issue(s)
Whether the guilt of the accused-appellant for statutory rape was proven beyond reasonable doubt. Whether the Court of Appeals erred in affirming the trial court's conviction despite alleged inconsistencies and questionable credibility of prosecution witnesses, including alleged ill motive of prosecution witnesses, and whether the accused-appellant's defense of denial should be given weight over the positive identification by the private complainant. Whether the crime should be classified as statutory rape under the Revised Penal Code and not in relation to Republic Act No. 7610.
Ruling
The Supreme Court affirmed the conviction of the accused-appellant but modified the classification of the crime. The accused-appellant is found guilty of Statutory Rape under Article 266-A(1)(d) of the Revised Penal Code, as amended, and is sentenced to suffer the penalty of reclusion perpetua. The monetary awards for civil indemnity, moral damages, and exemplary damages were affirmed with modification by the Court of Appeals and are to bear interest. The dispositive portion of the Supreme Court's decision is as follows: "WHEREFORE, the appeal is hereby DISMISSED. The Decision dated September 27, 2018 of the Court of Appeals in CA-G.R. CR-BC No. 08749 is AFFIRMED with MODIFICATION that accused-appellant XXX is hereby found guilty of Statutory Rape under Article 266(A)(1)(d) of the Revised Penal Code. He is sentenced to suffer the penalty of reclusion perpetua and to pay AAA ₱75,000 as civil indemnity, ₱75,000.00 as moral damages, and ₱75,000.00 as exemplary damages. All monetary awards shall bear interest at the rate of six percent (6%) per annum from finality of this Decision until fully paid."
Ratio Decidendi
On the issue of guilt for statutory rape: The Court held that the prosecution sufficiently proved beyond reasonable doubt that the accused-appellant had carnal knowledge of the private complainant, who was only eight (8) years old at the time of the incident. The private complainant's positive identification of the accused-appellant and her candid testimony were corroborated by the medical findings of hymenal lacerations reported by Dr. Guzman, which were consistent with sexual intercourse. The victim's age was established by her birth certificate. The Court reiterated that for statutory rape under Article 266-A(1)(d) of the RPC, the only elements to be proven are carnal knowledge of the victim and the victim's age being below twelve (12) years old. The presence of force or intimidation is not necessary when the victim is under twelve years of age. On the credibility of witnesses and the defense of denial, including alleged ill motive of prosecution witnesses: The Court found no compelling reason to reverse the factual findings of the trial and appellate courts regarding the credibility of the witnesses. The Court emphasized that findings of fact by the RTC, especially when affirmed by the CA, are accorded high respect. The accused-appellant's insistence that the private complainant did not behave normally during and after the rape, and her alleged failure to report the incident immediately, were rejected. The Court cited jurisprudence stating that there is no standard form of behavior for a rape victim, particularly a minor under the moral ascendancy of the perpetrator. The defense of denial was deemed inherently weak and could not prevail over the positive identification by the private complainant. The Court dismissed the accused-appellant's claim of ill motive on the part of witness CCC, noting that it was unsubstantiated. The Court reiterated the presumption that in the absence of evidence of improper motive, none exists. It also highlighted the implausibility of a mother sacrificing her daughter's reputation for the sake of a relative. On the classification of the crime: The Court, citing People v. Tulagan, clarified that when the offended party is under twelve (12) years of age, the crime is statutory rape under Article 266-A(1)(d) of the RPC, penalized under Article 266-B of the RPC. The Court ruled that there is a need to fix the nomenclature of the crime and that the correlation to RA 7610 should be deleted when the offense falls squarely under the RPC provisions for statutory rape. The Court explained that while RA 7610 provides special protection to children, the RPC, as amended by RA 8353, is the more recent and special penal legislation dealing with rape cases and imposes a more severe penalty, aligning with the intent to provide stronger deterrence and protection against child abuse.
Main Doctrine
Sexual intercourse with a victim under twelve (12) years of age constitutes statutory rape under Article 266-A(1)(d) of the Revised Penal Code, regardless of the presence of force or intimidation, and is penalized under Article 266-B of the Revised Penal Code. The correlation to RA 7610 is deleted when the offense falls squarely under the RPC provisions for statutory rape.