PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, v. JERRY COMILANG y BALLESTEROS, Accused-Appellant. G.R. No. 213853, July 29, 2019.

FACTS:
Jerry Comilang was charged with the crime of Rape under Article 266-A of the Revised Penal Code. The prosecution’s case relied primarily on the testimony of the private complainant, AAA, who was 12 years old at the time of the alleged incident. AAA testified that Comilang, a neighbor, forcibly had sexual intercourse with her inside his house. The defense, on the other hand, interposed denial and alibi, claiming Comilang was elsewhere during the alleged rape. The Regional Trial Court convicted Comilang of rape and sentenced him to reclusion perpetua. The Court of Appeals affirmed the conviction. Comilang appealed to the Supreme Court, arguing that the prosecution failed to prove his guilt beyond reasonable doubt, citing alleged inconsistencies in AAA’s testimony and the lack of medical evidence.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellant Jerry Comilang for the crime of rape, despite alleged inconsistencies in the victim’s testimony and the absence of medical evidence.

RULING

NO. The Court of Appeals did not err. The conviction is affirmed.

The Supreme Court held that the testimony of the victim, AAA, was credible, categorical, and consistent on material points. The alleged inconsistencies pertained to minor details which did not undermine the core narrative of forcible sexual intercourse. The Court emphasized that in rape cases, the credibility of the victim is of paramount importance. A young girl’s revelation of rape, coupled with her willingness to undergo the ordeal of a public trial, is itself a strong indication of the truth of her claim.

The absence of medical evidence, such as a healed hymenal laceration, is not fatal to the prosecution’s case. Medical findings are merely corroborative and not indispensable for a conviction, especially where the victim’s testimony is credible and positive. Rape can be proven by the sole testimony of the victim if it meets the test of credibility. Furthermore, the defense of denial and alibi, unsupported by clear and convincing evidence, cannot prevail over the positive identification and affirmative testimony of the victim.

The crime was properly qualified as rape under Article 266-A(1)(a) (by having carnal knowledge of a woman through force or intimidation) in relation to Article 266-B (on penalties), as the victim was under 18 years old at the time. The penalty of *reclusion perpetua* without eligibility for parole was correctly imposed pursuant to the law. The Court also affirmed the awards of civil indemnity, moral damages, and exemplary damages in accordance with prevailing jurisprudence.