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Issues
1. Whether the trial court erred in finding ill motive on the part of AAA as the reason for the filing
of the rape case against the accused-appellant
2. Whether the trial court gravely erred in finding the accused-appellant guilty beyond reasonable
doubt of the rape
Held/Rationale
The appeal has no merit and dismissed.
1. The trial court did not err in finding ill motive on the part of AAA as the reason for the filing of
the rape case.
The testimony of the victim is usually given confidence and weight in rape cases. The credibility
of witnesses in rape cases are given weight and respect and their testimonies are used as bases in
deciding. AAA’s testimony, as decided by the lower courts, was natural, convincing, and
consistent with the normal course of things. Although the accused raised the inconsistencies of
her testimony as a basis to dismiss the rape charge, the Court found it natural for the victim to
have inconsistencies when recalling the crime. It is in the human nature to feel stressed,
frightened, or angry after undergoing such heinous crime and trauma at such a young age. The
actions of the victim after the incident were also normal when she immediately confided in her
brother, who is a family member, and probably a close and trusted person for the victim. AAA
also immediately filed charges and underwent medical examination on the same day that the
crime happened.
2. The trial court did not err in finding the accused appellant guilty beyond reasonable doubt of the
rape charge.
a. The crime of rape was proven beyond reasonable doubt by prosecution. Going back to
the elements of rape, 1) the accused had carnal knowledge of the victim and the said act
was accomplished a) through force and intimidation. The evidences presented by the
prosecution validates these. The use of physical force to stop AAA from escaping the
room such as pinning her down, pinching her shoulder, mounting her, and the use of the
knife to threaten her and to later have carnal knowledge of her proved the crime of rape.
b. The defense given by the accused-appellant was inherently weak. The accused denied the
charges made against him, but his alibi was weak. In his alibi, he was still at the scene of
the alleged crime and it would not be impossible for him to commit the crime. A person
committing a crime of rape had no respect for the victim’s consent and body. Surely, the
presence of the wife presumably watching television and the boarder in the other rooms,
would not have stopped him from violating the minor nanny. Lastly, Jane and Erickson,
the only other people he claimed to be with him during this time and that could have
proven his alibi, did not give any testimonies to support his claim.
The Supreme Court believes that the lower courts did not err in sanctioning the accused with
reclusion perpetua in accordance with Article 266-B of the RPC. However, damages to be paid
were modified in line with the jurisprudence in People vs. Jugueta, with civil indemnity, moral
damages, and exemplary damages at P75,000 each. These shall be paid with six percent (6%) per
annum from the date of the finality of this judgment until fully paid.