People v. CCC

 

People v. CCC

G.R. No. 239336

June 3, 2019

FACTS:

                The RTC and CA convicted CCC for the crime of qualified rape. Sometime in September 2009, when AAA was 10 years old, she was sleeping inside their house with her sibling and their parents when at past midnight, she was awakened because she felt appellant inserting his erect penis into her vagina and succeeded in doing so, against her will. AAA was not able to shout for help because she was shocked and did not know what to do. She then felt pain in her vagina until appellant pulled his penis out. Thereafter, appellant put AAA's pajama back on. The same deed happened between AAA and the appellant less than ten (10) times on different occasions until AAA' s mother, BBB and some church members noticed that AAA' s belly was getting bigger. BBB brought AAA to a "hilof' who told them that AAA was pregnant prompting BBB to bring her daughter to a clinic for an ultrasound procedure to determine if she was really pregnant. The result of the ultrasound procedure showed that AAA was, indeed, pregnant. When BBB confronted AAA about her pregnancy, AAA told her mother that appellant was the one who had been having sexual intercourse with her. Thus, appellant left their house and stayed in another house. AAA eventually gave birth to a child at a hospital. The custody of AAA's child was then transferred to the Department of Social Welfare and Development.

ISSUE:

                Whether or not the CA erred in affirming the RTC

HELD:

                No. In reviewing rape cases we are guided by the following wellentrenched principles: (1) an accusation for rape can be made with facility: it is difficult to prove but more difficult for the person accused, though innocent, to disprove it; (2) in view of the intrinsic nature: of the crime of rape where only two persons are usually involved, the testimony of the complainant must be scrutinized with extreme caution; and (3) the evidence for the prosecution must stand or fall on its own merits, and cannot be allowed to draw strength from the weakness of the evidence for the defense. The determination of the credibility of the offended party's testimony is a most basic consideration in every prosecution for rape, for the lone testimony of the victim, if credible, is sufficient to sustain the verdict of conviction. As in most rape cases, the ultimate iissue in this case is credibility. In this regard, when the issue is one of credibility of witnesses, appellate courts will generally not disturb the findings of the trial court, considering that the latter is in a better position to decide the question as it heard the witnesses themselves and observed their deportment and manner of testifying during trial. The exceptions to the rulle are when such evaluation was reached arbitrarily, or when the trial court overlooked, misunderstood or misapplied some facts or circumstance of weight and substance which could affect the result of the case. None of these circumstances are present in the case at bar to warrant its exception from the coverage of this rule. It is well-established that when a woman says that she has been raped, she says, in effect, all that is necessary to show that she has indeed been raped. A victim of rape would not come out in the open if her motive were anything other than to obtain justice. Her testimony as to who abused her is credible where she has absolutely no motive to incriminate and testify against the accused, as in this case where the accusations were raised by private complainant against her own father. Anent appellant's defense of denial, bare assertions thereof cannot overcome the categorical testimony of the victim. Denial is an intrinsically weak defense which must be buttressed with strong evidence of nonculpability to merit credibility. Wherefore, CCC’s appeal is dismissed. CCC, convicted of Qualified Rape under Art. 266-A (1) in relation to Art. 266-B of the RPC.