GR 214473; (June, 2016) (Digest)
G.R. No. 214473 June 22, 2016
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. EMETERIO MEDINA Y. DAMO, Accused-Appellant.
FACTS
Accused-appellant Emeterio Medina was charged with the qualified rape of his four-year-old neighbor and relative, AAA, on May 9, 2000. The prosecution established that while AAA was on an errand, Medina pulled her into his house, led her to a room, removed her underwear, and had carnal knowledge of her. AAA, then a child, felt pain and cried but was threatened not to shout. She later reported the incident to her mother, BBB, who initially doubted her until AAA described details of the assault. BBB subsequently had AAA medically examined.
The medical examination revealed a fresh 0.4 cm laceration on the right lateral aspect of AAA’s hymen. Expert testimony from Dr. Pastrana stated such an injury was very rare for a child and highly improbable to be caused by an accident. A cytology report by Dr. La Madrid further indicated inflammation and infectious organisms consistent with vaginal trauma or insertion. The defense relied solely on Medina’s denial and alibi, claiming he was at a wedding and that the accusation stemmed from AAA’s envy.
ISSUE
Whether the Court of Appeals correctly affirmed the conviction of accused-appellant Emeterio Medina for the crime of Qualified Rape.
RULING
Yes, the conviction is affirmed. The Supreme Court upheld the findings of the lower courts, ruling that all elements of qualified rape were proven beyond reasonable doubt. Under Article 266-A of the Revised Penal Code, as amended, carnal knowledge with a woman under twelve years of age constitutes statutory rape. It was stipulated that AAA was only four years old at the time of the incident, thus her age alone establishes the crime. Her credible and categorical testimony, consistent with her childhood recollection, detailed the sexual assault. The medical findings of a fresh hymenal laceration corroborated her account, rendering the defense of denial and alibi weak and unavailing.
The crime is qualified under Article 266-B, as the victim was below seven years old. The proper penalty is reclusion perpetua without eligibility for parole, pursuant to Republic Act No. 9346 . The Court modified the damages, awarding AAA ₱100,000.00 as civil indemnity, ₱100,000.00 as moral damages, and ₱100,000.00 as exemplary damages, all with legal interest. The Court emphasized that the testimony of a child-victim, when credible, is sufficient to sustain a conviction for rape.