PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. JERRY COMILANG Y BAYUBAY, Accused-Appellant. G.R. No. 213853, July 29, 2019.

FACTS:
Accused-appellant 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 incident. AAA testified that Comilang, her neighbor, forcibly had sexual intercourse with her inside his house. The defense interposed the denial and alibi of the accused, claiming he was elsewhere at the time. The Regional Trial Court (RTC) found Comilang guilty beyond reasonable doubt and sentenced him to reclusion perpetua. The Court of Appeals (CA) affirmed the RTC’s decision in toto. Comilang appealed to the Supreme Court.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of the accused-appellant for the crime of rape based on the credibility of the victim’s testimony.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the conviction of accused-appellant Jerry Comilang. The Court held that the findings of the trial court on the credibility of witnesses, especially in rape cases, are accorded great weight and respect, as it had the direct opportunity to observe their demeanor and manner of testifying. The Court found no reason to deviate from these findings.

The testimony of AAA was found to be credible, straightforward, and consistent on material points. Her testimony alone, if credible, is sufficient to sustain a conviction for rape. The Court emphasized that when a young girl, particularly one of tender age, testifies that she has been raped, she says in effect all that is necessary to prove the commission of the crime. The defense of denial and alibi, which are inherently weak defenses, cannot prevail over the positive and categorical identification by the victim.

Furthermore, the Court noted that the medical findings, while not conclusive, were consistent with AAA’s account of a recent sexual encounter. The element of force and intimidation was also established, given the victim’s age, the difference in size and strength between her and the accused, and the circumstances of being alone with him inside his house.

The penalty of *reclusion perpetua* without eligibility for parole was correctly imposed, in accordance with Article 266-B of the Revised Penal Code, as amended by Republic Act No. 8353 and Republic Act No. 9346 . The Court also affirmed the awards of civil indemnity, moral damages, and exemplary damages to the victim, in line with prevailing jurisprudence.