People vs. Delos Santos

G.R. No. 186499 (March 21, 2012)

Facts:

The case involves Melecio de los Santos, Jr., who was charged with two counts of statutory rape against AAA, a minor. The first incident occurred on February 14, 1995, when AAA was 11 years old. The accused, who was the younger brother of AAA's mother, allegedly took advantage of the absence of AAA's parents and threatened her with a knife to force her to undress and engage in sexual intercourse. The second incident took place in September 1995, under similar circumstances, where the accused again threatened AAA with a knife and raped her.

During the trial, AAA testified about both incidents, detailing the threats made by the accused and the fear that prevented her from reporting the abuse immediately. She eventually disclosed the incidents to her family years later, after which her father, CCC, took action by bringing her to a medical facility for examination and filing a police report.

The prosecution presented several witnesses, including AAA's father, a physician who examined AAA, and her younger sister, BBB, who corroborated AAA's account of the first incident. The defense, on the other hand, relied solely on the testimony of the accused, who denied the allegations and claimed he was not present during the incidents, asserting that he was in another location attending to his sick adoptive father.

The Regional Trial Court (RTC) found the accused guilty of one count of statutory rape (Criminal Case No. CBU-51855) and acquitted him of the second count (Criminal Case No. CBU-51856) due to insufficient evidence. The RTC sentenced him to reclusion perpetua and ordered him to pay damages to AAA.

The accused appealed the decision to the Court of Appeals, which affirmed the RTC's ruling, leading to the present appeal before the Supreme Court.

Legal Issues:

  1. Whether the prosecution proved the guilt of the accused-appellant beyond a reasonable doubt for the crime of statutory rape.
  2. Whether the trial court erred in giving credence to the testimonies of the prosecution witnesses while disregarding the defense's evidence.

Arguments:

  • Prosecution's Arguments:

    • The prosecution argued that the testimonies of AAA and her witnesses were credible and consistent, establishing the accused's guilt beyond a reasonable doubt.
    • The medical examination corroborated AAA's claims of sexual abuse, as it revealed physical evidence consistent with rape.
    • The prosecution contended that the age of AAA at the time of the incidents was proven through her birth certificate, which was presented in court.

  • Defense's Arguments:

    • The defense maintained that the accused was not present during the alleged incidents and provided an alibi, claiming he was in another location.
    • The defense argued that the prosecution failed to meet the burden of proof required in criminal cases, emphasizing that the testimonies of the witnesses were inconsistent and lacked corroboration.
    • The accused-appellant asserted that the prosecution witnesses had motives to fabricate the charges against him.

Court's Decision and Legal Reasoning:

The Supreme Court upheld the decision of the Court of Appeals, affirming the RTC's conviction of the accused for statutory rape. The Court emphasized the following points in its reasoning:

  1. Credibility of Witnesses: The Court found the testimonies of AAA and her sister BBB credible, noting that minor inconsistencies in their accounts did not detract from the overall truth of the allegations. The Court reiterated that the testimonies of child victims are given full weight, as they are often straightforward and sincere.

  2. Proof of Age and Commission of Rape: The Court confirmed that the prosecution established AAA's age through her birth certificate, which indicated she was below 12 years old at the time of the first incident. The Court reiterated that in statutory rape cases, the consent of the victim is immaterial due to the presumption of incapacity to consent.

  3. Rejection of Alibi: The Court found the accused's alibi unconvincing, as it was not supported by substantial evidence. The mere denial of the accused was insufficient to overcome the positive identification made by the victim and corroborated by other witnesses.

  4. Damages Awarded: The Court affirmed the RTC's award of civil indemnity and moral damages to AAA, increasing the exemplary damages to P30,000. The Court also mandated legal interest on all damages awarded.

Significant Legal Principles Established:

  • The presumption of incapacity to consent in statutory rape cases, where the victim is below 12 years of age, renders the use of force or intimidation immaterial.
  • The credibility of child witnesses is paramount, and minor inconsistencies in their testimonies do not undermine the overall truth of their accounts.
  • The burden of proof in criminal cases lies with the prosecution, but the defense's mere denial or alibi must be substantiated with credible evidence to be persuasive.