G.R. No. 210619 , August 20, 2014
People of the Philippines, Plaintiff-Appellee, vs. Charles Reyes y Marasigan, Accused-Appellant.

FACTS

Accused-appellant Charles Reyes y Marasigan was convicted by the Regional Trial Court (RTC) of two counts of rape committed against AAA, the 11-year-old daughter of his common-law wife, BBB. The first incident occurred sometime in May 2002, and the second on August 5, 2002, in Calapan City. The prosecution presented AAA’s testimony detailing that the accused-appellant, through force and intimidation, undressed and mounted her, attempting to and succeeding in inserting his penis into her vagina, causing her pain. Her mother BBB and Dr. Ma. Teresita Nieva-Bolor, who conducted a medical examination on August 6, 2002, also testified. The medical certificate indicated vulvar erythema and hymenal lacerations. The defense consisted of the accused-appellant’s denial, claiming the charges were fabricated after he drove BBB and her children from their home, and the testimony of his niece, Princess Ann Sicat, who claimed AAA was with her the entire day of August 5, 2002. The RTC found AAA’s testimony credible and convicted the accused-appellant, sentencing him to two counts of reclusion perpetua and ordering him to pay damages. The Court of Appeals affirmed the RTC decision in toto.

ISSUE

Whether the Court of Appeals correctly affirmed the conviction of the accused-appellant for two counts of qualified statutory rape.

RULING

The Supreme Court affirmed the conviction with modifications. The Court held that the elements of qualified statutory rape were present: AAA was under 12 years of age (11 years old), and the accused-appellant, as the common-law husband of AAA’s mother, was a stepfather within the scope of Article 266-B of the Revised Penal Code, making the crime qualified. The Court found AAA’s testimony, given in a clear and straightforward manner, credible and sufficient to establish the fact of rape. The medical findings, though indicating healed lacerations, corroborated her account. The defense of denial and alibi could not prevail over the positive identification and credible testimony of the victim. The Court modified the penalties and damages in accordance with prevailing jurisprudence: for each count of qualified statutory rape, the penalty of reclusion perpetua without eligibility for parole was imposed. The accused-appellant was ordered to pay AAA ₱75,000.00 as civil indemnity and ₱30,000.00 as exemplary damages for each count, with interest at 6% per annum on all damages from the finality of judgment until fully paid.