Facts:

The case revolves around the sexual assault of Lorelie Trinidad, a young girl who was under twelve years of age at the time of the incidents. The accused, Romeo Oarga, was the live-in partner of Lorelie's mother, Josephine Trinidad, and thus stood in a position of trust and authority over Lorelie. The first incident occurred on the night of May 20, 1990, when Oarga woke Lorelie while she was asleep, ordered her to undress, and then sexually assaulted her while threatening her with a fan-knife. Despite her pleas for him to stop, he continued the assault, which left her traumatized.

The second incident took place on June 3, 1990, when Oarga again summoned Lorelie to a secluded area of the house, turned off the lights, and repeated the sexual assault in a similar manner. Following these traumatic experiences, Lorelie left her home and moved to Lumban, Laguna. It was not until December 1, 1990, that she disclosed the abuse to her mother, citing fear of Oarga's threats against her life. Subsequently, Josephine Trinidad filed two complaints for rape against Oarga, leading to a trial where he was found guilty of both counts.

Legal Issues:

  1. Whether the trial court erred in giving credence to the testimony of Lorelie Trinidad.
  2. Whether the evidence presented was sufficient to establish Oarga's guilt beyond reasonable doubt for the crime of rape.

Arguments:

  • Prosecution's Argument: The prosecution maintained that Lorelie's testimony was credible and corroborated by medical evidence. They argued that the absence of physical resistance or outcry from Lorelie did not negate the occurrence of rape, especially given her age and the circumstances of intimidation under which the assaults occurred.

  • Defense's Argument: The defense contended that Lorelie's testimony was not credible, arguing that her failure to scream or call for help during the assaults was inconsistent with human behavior. They claimed that her lack of resistance indicated that the incidents did not constitute rape.

Court's Decision and Legal Reasoning:

The court affirmed the trial court's decision, finding no error in its judgment. It emphasized that under Article 335 of the Revised Penal Code, the mere fact that Lorelie was under twelve years of age at the time of the assaults was sufficient to establish the crime of rape, regardless of the presence of force or intimidation. The court noted that intimidation is subjective and must be assessed based on the victim's perception during the assault.

The court found that Oarga's threats with the knife constituted intimidation, which was sufficient to establish the crime. The court also highlighted that Lorelie's testimony was straightforward and corroborated by medical findings of penetration, thus supporting the conclusion of carnal knowledge. The court ruled that the credibility of the victim's testimony should not be doubted, especially given the absence of any motive for her to fabricate the allegations.

Significant Legal Principles Established:

  1. The age of the victim is a critical factor in determining the commission of rape; if the victim is under twelve years old, the absence of force or intimidation does not negate the crime.
  2. Intimidation can be subjective and is assessed based on the victim's perception during the assault.
  3. The testimony of a rape victim, particularly a minor, is entitled to full credence when corroborated by medical evidence and when there is no apparent motive to lie.