43. People vs. Bonaagua, GR No.

188897, June 06, 2011

Facts:

This case involves the appeal of Ireno Bonaagua (Ireno) against his conviction for three
counts of statutory rape and acts of lasciviousness. The charges were filed against Ireno
by the Office of the City Prosecutor of Las Piñas City based on the allegations made by
his minor daughter, AAA. AAA accused Ireno of inserting his tongue and finger into her
genitals on multiple occasions.

During the trial, the prosecution presented testimonies from AAA, her mother, and Dr.
Melissa De Leon. The defense, on the other hand, presented the testimony of Ireno. The
prosecution's evidence included AAA's detailed account of the incidents and the medical
examination conducted by Dr. De Leon, which revealed a healed superficial laceration
on AAA's hymen.

The Regional Trial Court (RTC) found Ireno guilty of four counts of rape and sentenced
him to reclusion perpetua for each count. The RTC also ordered him to pay AAA
Php50,000 for each count as civil indemnity and moral damages. Ireno appealed the
decision to the Court of Appeals (CA), which affirmed the RTC's decision with
modifications. The CA found Ireno guilty of acts of lasciviousness in one count instead
of rape due to the lack of evidence of finger insertion. The CA also modified the penalties
imposed by the RTC.

Ireno appealed to the Supreme Court, arguing that the prosecution failed to prove his
guilt beyond reasonable doubt. He claimed that AAA's testimony was inconsistent and
unbelievable, and that the medical findings were inconclusive. However, the Supreme
Court rejected Ireno's arguments, stating that the trial court's assessment of the
credibility of witnesses deserves great weight and respect. The Court emphasized that
the testimony of the victim in a rape case, if credible, is enough to sustain a conviction.
The Court also noted that the medical findings supported AAA's claim of sexual abuse.

Issue:

The main issue in this case is whether the prosecution was able to prove Ireno's guilt
beyond reasonable doubt for the charges of statutory rape and acts of lasciviousness.

Ruling:
The Supreme Court affirmed the decision of the Court of Appeals, finding Ireno guilty of
three counts of statutory rape and acts of lasciviousness. The Court upheld the penalties
imposed by the CA and ordered Ireno to pay the corresponding damages to AAA.

Ratio:

The Supreme Court rejected Ireno's arguments that the prosecution failed to prove his
guilt beyond reasonable doubt. The Court emphasized that the trial court's assessment
of the credibility of witnesses deserves great weight and respect. In this case, AAA's
testimony was found to be credible and consistent, providing detailed accounts of the
incidents. The Court also noted that the medical findings, specifically the healed
superficial laceration on AAA's hymen, supported AAA's claim of sexual abuse.

The Court further explained that in rape cases, the testimony of the victim, if credible, is
enough to sustain a conviction. The Court recognized the vulnerability of victims of
sexual abuse, especially minors, and the difficulty they face in recounting traumatic
experiences. In this case, AAA's testimony was found to be credible and consistent,
providing sufficient evidence to establish Ireno's guilt.

Regarding the charges of acts of lasciviousness, the Court agreed with the CA's
modification, finding that there was a lack of evidence to establish the insertion of a
finger into AAA's vagina. However, Ireno was still found guilty of acts of lasciviousness
for touching AAA's breasts and licking her vagina.

In terms of penalties, the Court upheld the penalties imposed by the CA. For the charges
of statutory rape, the Court affirmed the imposition of reclusion perpetua for each
count. For the charge of acts of lasciviousness, the Court applied the penalties under
Section 5 (b) of R.A. No. 7610. The Court clarified that the reasoning in a previous case
for imposing the higher penalty under R.A. No. 7610 did not apply in this case.
44. People of the Philippines Vs. Leonardo Quiapo, G.R. No. 218804. August
6, 2018

Facts:

● Appellant Leonardo Quiapo was charged with six counts of rape under Article
335 of the Revised Penal Code.
● The charges were based on separate incidents involving two victims, AAA and
MMM.
● The incidents occurred in Zamboanga del Norte in 1996.
● The prosecution presented the testimonies of AAA and MMM, who both claimed
that appellant had sexually abused them.
● The defense of appellant was denial and alibi, claiming that he was not present at
the time and place of the incidents.
● The Regional Trial Court (RTC) found appellant guilty of one count of attempted
rape and five counts of consummated rape.
● The Court of Appeals (CA) affirmed the RTC's decision with modifications.

Issue:

● Whether the testimonies of AAA and MMM are credible and sufficient to
establish appellant's guilt beyond reasonable doubt.

Ruling:

● The appeal is dismissed.

● The testimonies of AAA and MMM are credible and sufficient to establish
appellant's guilt beyond reasonable doubt.
● The courts below correctly rejected appellant's defenses of denial and alibi.
● The delay in reporting the incidents does not undermine the credibility of AAA
and MMM.
● The discrepancies in the dates, place, and time of the incidents are not grounds
for acquittal.
● The Court agrees with the CA that appellant should be held liable for statutory
rape in Criminal Case Nos. L-0098 and L-0099.
● The Court finds no compelling reason to deviate from the findings of the CA
affirming that of the trial court.
● The Court modifies the amount of damages awarded by the CA.
● The prison term for attempted rape in Criminal Case No. L-0100 is sustained, but
the award of damages is modified.
Ratio:

● The issue of credibility of witnesses is best addressed to the trial court, and the
reviewing court is generally bound by its findings, especially when no significant
facts and circumstances are shown to have been overlooked or disregarded.
● The date of the commission of the rape is not an essential element of the crime,
and inconsistencies in details irrelevant to the elements of the crime are not
grounds for acquittal.
● Delay in reporting rape incidents, in the face of threats of physical violence,
cannot be taken against the victim and does not cast doubt on the credibility of
the complainant.
● A mere denial, without strong evidence to support it, cannot overcome the
positive declaration of the victim regarding the identity and involvement of the
accused.
● Motives such as resentment, hatred, or revenge do not affect the credibility of a
minor rape victim's testimony.
● The elements of statutory rape are carnal knowledge of a woman and the woman
being under 12 years of age or demented.
● The penalty for statutory rape is reclusion perpetua, while the penalty for simple
rape is also reclusion perpetua.
● The amount of damages awarded should be modified in line with recent
jurisprudence.
45. People vs. Pareja, G.R. No. 202122, January 15, 2014

Facts:

The accused-appellant, Bernabe Pareja y Cruz, is appealing the decision of the Court of
Appeals affirming his conviction for Rape and Acts of Lasciviousness. Pareja was
charged with two counts of Rape and one count of Attempted Rape. The incidents
allegedly occurred in December 2003, February 2004, and March 27, 2004. The victim,
AAA, was 13 years old at the time of the incidents. AAA's parents had separated when
she was 8 years old, and she was living with her mother and Pareja, who was her
mother's common-law spouse. AAA reported the incidents to the barangay officials and
underwent a medical examination, which confirmed the presence of blunt force or
penetrating trauma. Pareja denied the charges and claimed that AAA filed the charges
out of revenge for being the reason behind her parents' separation.

Issue:

1. Whether Pareja's guilt has been proven beyond reasonable doubt.

2. Whether the trial court erred in convicting Pareja based solely on AAA's
testimony.

Ruling:

The Court finds no reason to reverse Pareja's conviction. The trial court's evaluation of
the credibility of witnesses is given the highest respect, and absent any substantial
reason to reverse the trial court's findings, the appellate court is generally bound by the
lower court's findings. Inconsistencies in a rape victim's testimony are generally
expected, and the inconsistencies mentioned by Pareja are trivial and
non-consequential. The court also notes that the victim's demeanor and conduct after
the incidents do not negate the possibility that she was raped, as victims of rape cannot
be expected to act within reason or in accordance with society's expectations. The court
also finds that the medical examination, although not indispensable, bolsters the
victim's claim of being raped.

Ratio:

The court gives deference to the trial court's evaluation of witness credibility.
Inconsistencies in a rape victim's testimony are expected and do not necessarily
undermine the victim's credibility. The victim's demeanor and conduct after the
incidents cannot be used to discredit her, as victims of rape may not act within reason or
in accordance with societal expectations. A medical examination is not necessary to
prove the commission of rape, and expert testimony is merely corroborative in character
and not essential to conviction.
46. People vs. Espera, G.R. No. 202868, October 02, 2013

Facts:

This case involves the appellant, Michael Espera, who was accused of committing the
crimes of rape by sexual assault and rape by sexual intercourse against the victim, Ana.
The incidents occurred on January 26, 1999, in the municipality of Ubay, Bohol,
Philippines. Ana and her co-worker, Susie, decided to share a ride home after work.
They hailed a tricycle driven by the appellant, whom Susie recognized as one of her
husband's friends. Ana recognized the appellant by face but did not know his name.
When they reached Barangay Ekis, Susie disembarked first, and Ana asked the appellant
to stop the tricycle near her house. However, the appellant continued driving, claiming
that the tricycle's brakes were not working. Eventually, the tricycle stopped at a quarry
site, and the appellant asked Ana to get off, stating that the tricycle had run out of gas.
Ana offered to pay her fare, but the appellant refused. As Ana was walking home, she
heard someone following her. She turned around and saw the appellant, who was
partially naked and holding a gun. The appellant chased Ana, caught her, covered her
mouth, and threatened to kill her if she shouted. He then proceeded to sexually assault
and rape her. The next day, Ana reported the incident to her mother and later informed
Susie. Ana underwent a medical examination, which revealed injuries consistent with
her account of the assault. The appellant was eventually apprehended in Pampanga in
August 2003.

Issue:

The main issue in this case is whether the guilt of the appellant, Michael Espera, was
proven beyond reasonable doubt for the crimes of rape by sexual assault and rape by
sexual intercourse.

Ruling:

The Court of Appeals affirmed the decision of the Regional Trial Court (RTC) finding the
appellant guilty of the crimes charged. The appellant's appeal was denied, and the RTC's
decision was modified only in terms of the damages awarded to the victim.

Ratio:

The Court of Appeals found that the prosecution had proven beyond reasonable doubt
that the appellant committed the crimes of rape by sexual assault and rape by sexual
intercourse against the victim. The court relied on the victim's detailed and consistent
testimony, which was supported by the medical examination showing injuries consistent
with her account of the assault. The court also considered the positive identification of
the appellant by the victim and her co-worker, as well as the appellant's sudden flight
from Ubay, Bohol, which indicated guilt. The court rejected the appellant's alibi and
denial, as well as his claim that the victim's behavior during the incident undermined
her credibility. The court concluded that the appellant's guilt was proven beyond
reasonable doubt.
47. People vs. Rivera, GR No. 200508, September 04, 2013

Facts:

This case involves an appeal from the decision of the Court of Appeals (CA) affirming
the judgment of the Regional Trial Court (RTC) finding the accused, Christopher Rivera,
guilty of rape. On October 4, 2004, an Information for Rape was filed against Rivera,
stating that on September 29, 2004, in Manila, he forcibly undressed the victim,
inserted his penis in her vagina, and had carnal knowledge of her against her will and
without her consent. The victim, referred to as AAA, testified that she was a 20-year-old
housemaid who met Rivera while working at the same place. Rivera offered to help her
find another job and on September 29, 2004, he brought her to a motel instead of his
parents' house as he had promised. Inside the motel room, Rivera forced her to undress
and raped her. She struggled and shouted for help, but no one heard her. After the
incident, they went to her cousin's house where she reported the incident to the police.
Rivera claimed that AAA was his girlfriend and that they went to the motel voluntarily.
He argued that AAA consented to the sexual act. A witness, Grace Due o, the cashier at
the motel, supported Rivera's version of events.

Issue:

The main issue raised in this case is whether or not the accused, Christopher Rivera, is
guilty of rape beyond reasonable doubt.

Ruling:

The Supreme Court upheld the conviction of Christopher Rivera for rape. The court
affirmed the decision of the lower courts, finding Rivera guilty beyond reasonable doubt.
The court rejected Rivera's claim of consent and emphasized that even if AAA and
Rivera were lovers, it did not give him the right to sexually assault her. The court
considered AAA's credible testimony, the evidence presented, and the lack of proof of a
romantic relationship between AAA and Rivera. The court concluded that there was no
reversible error in the lower courts' decisions and affirmed the conviction of Rivera for
rape. The court also upheld the damages imposed by the trial court.

Ratio:

The court emphasized that in rape cases, the credibility of the victim is crucial. In this
case, AAA's testimony was consistent and credible. The court also considered the size
and strength difference between AAA and Rivera, concluding that force was employed in
the commission of the crime. The court rejected Rivera's claim of consent, stating that
AAA's behavior after the assault should not be interpreted as consent. The court further
explained that resistance is not an element of rape and that the lack of physical
evidence, such as vaginal lacerations, does not negate sexual intercourse. The court
emphasized that the victim's perception and judgment at the time of the crime should be
considered, and that not all victims react the same way. The court also rejected Rivera's
defense of the "sweetheart theory," as he failed to provide convincing proof of a
relationship with AAA. The court upheld the trial court's assessment of witness
credibility and stated that it should be respected unless there are facts or circumstances
that were overlooked and would materially affect the case.
48. People vs. Rubio, G.R. No. 195239, March 7, 2012

Facts:

● Accused Ben Rubio y Acosta was charged with qualified rape before the Regional
Trial Court (RTC) in Pasig City.
● The victim, AAA, accused Rubio of raping her on January 8, 2000, when she was
15 years old.
● AAA testified that Rubio approached her while she was sleeping and forcibly had
sexual intercourse with her.
● AAA reported the incident to a neighbor and filed a complaint against her father.
● Dr. Emmanuel Reyes, a medico-legal expert, examined AAA and found evidence
of sexual assault.

Issue:

● Whether or not Rubio is guilty beyond reasonable doubt of the crime of rape.

Ruling:

● The Court of Appeals (CA) affirmed the decision of the RTC, finding Rubio guilty
of qualified rape.
● The Supreme Court upheld the ruling of the CA.

Ratio:

● In rape cases, the credibility of the victim is of utmost importance.

● The trial court's assessment of credibility is given great weight, as they have the
opportunity to directly observe the witnesses' demeanor and manner of
testifying.
● Inconsistencies in the victim's testimony are expected and do not necessarily
impair the credibility of the victim.
● Testimonies of child victims are given full weight and credit, as youth and
immaturity are generally badges of truth.
● The sole testimony of a rape victim, if credible, is sufficient to convict.
● The elements of qualified rape were duly proved, as the victim's testimony
established that Rubio had carnal knowledge of her through force and
intimidation.
● The aggravating circumstances of minority and relationship were stipulated upon
during pre-trial, eliminating the need for further proof during trial.
● Medical findings corroborated the victim's testimony, supporting the conclusion
that she had been subjected to sexual assault.