In a ruling that underscores the importance of protecting vulnerable individuals, the Supreme Court affirmed the conviction of Virgilio Antonio for two counts of rape against a minor, AAA. The court emphasized that the victim’s straightforward testimony, coupled with medical evidence, was sufficient to prove the accused’s guilt beyond reasonable doubt. This decision highlights the court’s commitment to upholding the rights of children and ensuring that perpetrators of sexual abuse are held accountable, even when there are minor inconsistencies in the victim’s statements.

When a Godfather Violates Trust: Weighing Testimony and Aggravating Circumstances in a Rape Case

The case of People of the Philippines v. Virgilio Antonio y Rivera began with two separate informations filed against the accused-appellant, Virgilio Antonio, before the Regional Trial Court (RTC) of Tuguegarao City. The charges stemmed from two alleged rape incidents against AAA, a minor. The first incident allegedly occurred sometime in 2001, where Antonio, with lewd designs and through force, threat, and intimidation, had sexual intercourse with AAA, who was then 14 years old. The information also cited the aggravating circumstance of the uninhabited place where the crime occurred. The second incident was said to have occurred on August 26, 2003, where Antonio, being AAA’s guardian, allegedly abused his position to commit the same crime.

At the arraignment, Antonio pleaded not guilty, setting the stage for a trial where the prosecution presented AAA’s testimony and medical findings to support the charges. During the pre-trial, the defense admitted to several stipulations, including Antonio’s identity, his relationship as AAA’s godfather, and AAA’s minority at the time of the alleged crimes. The prosecution’s case hinged on AAA’s detailed account of the incidents, supported by a medicolegal certificate prepared by Dr. Rafael Sumabat. On the other hand, the defense presented Antonio as the lone witness, denying the charges and claiming AAA only started living with them in May 2002.

The prosecution’s version, as summed up by the Office of the Solicitor General (OSG), painted a disturbing picture of abuse. In March 2001, AAA began living with Antonio’s family after her parents separated. In April 2001, Antonio took AAA to his farm in the highlands and, in a bamboo grove, threatened to kill her if she revealed what he was about to do. He then forced her to lie down and had sexual intercourse with her. The second incident occurred on August 26, 2003, when Antonio’s wife and children were away. Antonio allegedly entered AAA’s room and again forced himself on her.

In contrast, Antonio vehemently denied the charges, claiming AAA only lived with them from May 2002 and that he was not present during the alleged second incident as his wife and AAA had returned home drunk from a town fiesta on August 28, 2003. The RTC, however, found AAA’s testimony credible, noting she had no ill motive to testify against Antonio, whom she considered her guardian. The trial court found Antonio guilty beyond reasonable doubt for two counts of rape. The court sentenced him to reclusion perpetua for each case, along with civil indemnity, moral damages, and exemplary damages.

The case then moved to the Court of Appeals (CA), where Antonio challenged the RTC’s decision. He argued that inconsistencies in AAA’s testimony and the medical evidence cast doubt on her claims. He also questioned why AAA did not shout or try to escape during the alleged incidents. The OSG countered that AAA’s failure to shout should not affect her credibility, considering her age and the intimidation she faced from Antonio, her godfather. The CA affirmed Antonio’s conviction, albeit with modifications to the damages awarded. The appellate court emphasized that any inconsistency in AAA’s testimony regarding the date of her examination was not enough to destroy her credibility.

The CA also addressed the aggravating circumstances alleged in the informations. While the RTC considered the qualifying aggravating circumstance of guardianship, the CA clarified that the guardian must have a legal relationship with the ward, which was not the case here. The appellate court found the aggravating circumstances of the victim’s minority and the uninhabited place in the first count of rape. In the second count, only the minority of the victim was considered. The CA reduced the award of civil indemnity and moral damages but increased the exemplary damages. The Supreme Court affirmed the CA’s verdict, but modified the same by imposing interests upon the damages awarded to AAA.

The Supreme Court emphasized that the factual findings of the trial court, especially its assessment of the credibility of witnesses, are accorded great weight and respect, particularly when affirmed by the CA. For a conviction in rape cases, it must be proven beyond reasonable doubt that the accused had carnal knowledge of the victim and that said act was accomplished through force or intimidation or when the victim is twelve years of age, or is demented.

The Supreme Court found the RTC and CA’s factual findings sufficiently supported by evidence and jurisprudence. AAA’s testimonies on the two rape incidents were straightforward and categorical. The accused-appellant threatened her with death in April 2001, and in August 2003, Antonio abused his moral ascendancy over AAA. In physical examination, Dr. Sumabat found lacerations in AAA’s hymen, despite Antonio’s denials and alibi. As in People v. Laog, the Court held that minor discrepancies do not affect the veracity or detract from the essential credibility of witnesses’ declarations. Also, the Court agreed with the CA’s findings that only the generic aggravating circumstances of commission of the crime in an uninhabited place and minority can be appreciated relative to the first rape incident.

The Supreme Court sustained the penalty of reclusion perpetua imposed on Antonio for each of the two counts of rape committed. The aggravating circumstances of minority and commission of the crime in an uninhabited place were present. The Court also found proper the CA’s modification of the amount of civil indemnity and damages imposed by the RTC. To conform to prevailing jurisprudence, an interest of six percent (6%) per annum on all the damages awarded shall be imposed, to be computed from the date of the finality of this judgment until fully paid.

FAQs

What was the key issue in this case?	The key issue was whether the accused-appellant’s guilt for allegedly raping AAA on two separate occasions was proven beyond reasonable doubt, despite minor inconsistencies in the victim’s testimony and the medical evidence.
What was the crime the accused was charged with?	Virgilio Antonio was charged with two counts of rape under Article 335 of the Revised Penal Code, as amended by Republic Act 7659 and further amended by Republic Act No. 8353; and Article 266 (A) No. 1 in relation to Article 266 (B) No. 1 of the Revised Penal Code, as amended by Republic Act No. 8353.
What was the relationship between the accused and the victim?	The accused, Virgilio Antonio, was the victim’s godfather and, for a period, acted as her guardian, which created a position of trust that he was accused of violating.
What evidence was presented by the prosecution?	The prosecution presented AAA’s testimony detailing the rape incidents, a medicolegal certificate from Dr. Rafael Sumabat confirming physical findings, and AAA’s birth certificate to prove her minority.
What was the accused’s defense?	The accused denied the charges, claiming that the victim only started living with them later than the date of the first incident and that he was not at home during the second alleged incident.
What was the ruling of the Regional Trial Court (RTC)?	The RTC found Virgilio Antonio guilty beyond reasonable doubt for two counts of rape, sentencing him to reclusion perpetua for each count and ordering him to pay civil indemnity, moral damages, and exemplary damages to the victim.
How did the Court of Appeals (CA) modify the RTC’s decision?	The CA affirmed the conviction but modified the amounts of civil indemnity, moral damages, and exemplary damages, and clarified the appreciation of aggravating circumstances.
What aggravating circumstances were considered in the case?	The aggravating circumstances considered were the minority of the victim and the commission of the crime in an uninhabited place for the first count of rape, and the minority of the victim for the second count of rape.
What was the final ruling of the Supreme Court?	The Supreme Court affirmed the CA’s verdict with a modification directing Virgilio Antonio to pay interest at the rate of six percent (6%) per annum on all the damages awarded to AAA, to be computed from the date of the finality of the judgment until fully paid.

This case serves as a reminder of the courts’ dedication to safeguarding children and prosecuting those who exploit positions of trust. The decision reinforces the principle that even minor inconsistencies do not necessarily undermine the credibility of a victim’s testimony in cases of sexual abuse. The ruling should be applied to similar situations in the future, ensuring accountability for perpetrators and justice for victims.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: PEOPLE OF THE PHILIPPINES, VS. VIRGILIO ANTONIO Y RIVERA, G.R. No. 208623, July 23, 2014