G.R. No. 234514 , April 28, 2021
People of the Philippines, Plaintiff-Appellee, vs. Leopoldo Viñas y Maniego and Maricel Torres y Gonzales, Accused-Appellants.

FACTS

Accused-appellants Leopoldo Viñas and Maricel Torres were charged with the rape of AAA, a 17-year-old minor, on or about November 11, 2002, in San Simon, Pampanga. The Information alleged that Viñas, by means of force, threat, and intimidation, had carnal knowledge of AAA, with the cooperation of Torres who pinned down AAA’s feet and separated her legs to enable the rape. Both pleaded not guilty. The prosecution’s version established that AAA visited a relative on November 11, 2002, and later drank liquor with the appellants and another male until evening. After resting, AAA was called into the appellants’ room where she saw them naked and using shabu. She left, but Viñas followed, hit her, carried her back inside, and, with Torres’ help in holding AAA down and gagging her, raped her. Viñas threatened to stab AAA if she made noise and later threatened to kill her if she reported the incident. AAA reported the rape to her cousin and the police, and was medically examined on November 13, 2002. The defense claimed AAA and another visitor left their house in the evening of November 11, and they only learned of the rape charge later, with AAA allegedly stating it was due to Viñas not responding to her infatuation. The Regional Trial Court convicted both appellants of simple rape under Article 266-A of the Revised Penal Code, sentencing them to reclusion perpetua and ordering them to pay damages. The Court of Appeals affirmed the conviction but modified the damages awarded.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellants Leopoldo Viñas and Maricel Torres for the crime of rape.

RULING

The Supreme Court denied the appeal and affirmed the modified decision of the Court of Appeals. The Court held that the trial court’s factual findings, especially on the credibility of the rape survivor, are accorded great weight and respect. AAA’s testimony was found to be credible, natural, convincing, and consistent with human nature, which is sufficient to sustain a conviction for rape. The alleged inconsistencies in her testimony were deemed inconsequential to the material fact of the rape’s occurrence. The Court also ruled that the medical finding of healed lacerations does not negate rape, as medical examination is not indispensable for a rape conviction. Conspiracy between Viñas and Torres was established, as Torres’s actions in holding AAA down and gagging her showed a unity of purpose and design to commit the felony. The penalty of reclusion perpetua for each appellant was upheld. The awards of civil indemnity, moral damages, and exemplary damages were increased to P75,000.00 each, pursuant to prevailing jurisprudence, with interest at 6% per annum from the finality of the decision until full payment.