In People vs. Aguiluz, the Supreme Court affirmed that sexual intercourse with a minor under twelve years of age constitutes statutory rape, regardless of consent. The ruling underscores the law’s protective stance towards children, emphasizing their lack of capacity to give informed consent. This legal principle safeguards children from sexual exploitation, reflecting a commitment to protect their welfare and innocence.

When Caretaker Becomes Predator: Can Alibi Shield a Child Molester?

The case of People of the Philippines vs. Florante Aguiluz y Nuque revolves around the alleged rape of Elizabeth Cruz, a minor under the age of twelve, by Florante Aguiluz, who was a caretaker and lay minister. The prosecution presented evidence that Aguiluz, taking advantage of his position of trust, sexually assaulted Cruz in her own home. The defense countered with an alibi, claiming Aguiluz was at church during the time of the incident. The central legal question was whether the prosecution had proven beyond a reasonable doubt that Aguiluz committed statutory rape, despite the defense’s alibi and questions raised about the victim’s testimony and medical evidence.

At trial, Elizabeth Cruz testified that on October 15, 1995, Aguiluz lured her into a room in her house, where he sexually assaulted her. She recounted the details of the assault, including how Aguiluz closed the doors and windows, and despite her resistance, forced himself upon her. Cruz initially kept silent due to fear but eventually confided in friends and her teacher, leading to a formal complaint. A medical examination revealed healed lacerations on Cruz’s hymen, which the defense argued contradicted her claim of recent trauma. The prosecution argued that these lacerations, regardless of their age, did not negate the fact of rape, especially considering Cruz’s age and vulnerability.

Aguiluz presented an alibi, stating he was at San Antonio de Padua Parish Church, serving as a lay minister during the time of the alleged rape. To support this, he presented Fr. Irineo Cabasal. However, on cross-examination, Fr. Cabasal stated that the church only had one mass on Sundays, which occurred in the morning, thus undermining Aguiluz’s alibi. The trial court found Aguiluz guilty of statutory rape, emphasizing the credibility of Cruz’s testimony and the weaknesses in the defense’s alibi.

The Supreme Court affirmed the lower court’s decision, reiterating the elements of statutory rape under Article 335 of the Revised Penal Code. This provision states that rape is committed when a man has carnal knowledge of a woman under twelve years of age. The Court underscored that in cases of statutory rape, the victim’s consent is irrelevant. The law presumes a child under twelve lacks the capacity to give informed consent, thus making any sexual act with them unlawful. The Court emphasized that Elizabeth Cruz was under twelve when the crime occurred and that Aguiluz had carnal knowledge of her.

Building on this principle, the Court addressed the defense’s argument regarding the healed lacerations on Cruz’s hymen. It clarified that the absence of fresh lacerations does not negate the commission of rape. The Supreme Court affirmed that even healed lacerations are proof of prior sexual contact. The Court noted that penetration, even without rupture of the hymen, is sufficient to constitute rape. The crucial factor is the credibility of the victim’s testimony. The court explicitly stated, “A freshly broken hymen is not an essential element of rape. Healed lacerations do not negate rape.”

The Supreme Court also dismissed the defense’s claim that Cruz’s grandparents had concocted the rape charge due to ill feelings towards Aguiluz. The Court found no evidence to support this allegation and emphasized the lack of any ill motive on Cruz’s part to falsely accuse Aguiluz. The Court noted the unlikelihood that Cruz’s grandparents would subject her to the trauma of a rape trial simply to get back at Aguiluz. Furthermore, the Court discredited Aguiluz’s alibi, citing the proximity between his alleged location and the crime scene, and the conflicting testimony of his own witness, Fr. Cabasal. Given this, the Court found that Aguiluz’s alibi did not preclude the possibility of him committing the crime.

The Supreme Court affirmed the penalty of reclusion perpetua imposed by the trial court, in accordance with Article 335 of the Revised Penal Code, as amended by R.A. No. 7659. In addition to moral damages, the Court ordered Aguiluz to pay civil indemnity to the victim, emphasizing that these awards are based on distinct legal grounds and are within the court’s discretion. The case underscores the paramount importance of protecting children from sexual abuse and holding perpetrators accountable, regardless of their position or the absence of physical evidence such as fresh injuries.

FAQs

What is statutory rape?	Statutory rape is defined as sexual intercourse with a person who is under the legal age of consent, regardless of whether the act was consensual. In the Philippines, the legal age of consent is 12.
Does the victim’s consent matter in statutory rape cases?	No, the victim’s consent is irrelevant in statutory rape cases. The law presumes that a person under the legal age of consent lacks the capacity to give valid consent to sexual activity.
What are the key elements needed to prove statutory rape?	The key elements are proving that the accused had carnal knowledge of the victim and that the victim was under twelve years of age at the time of the act.
Does the absence of fresh injuries disprove a rape allegation?	No, the absence of fresh injuries, such as a freshly broken hymen, does not disprove a rape allegation. The Supreme Court has held that penetration without rupture of the hymen can still constitute rape.
What is the significance of “healed lacerations” in this case?	The presence of healed lacerations on the victim’s hymen, according to medical testimony, did not negate the possibility of rape. The Court recognized such as indication of prior sexual contact.
What role does the credibility of the victim play in statutory rape cases?	The credibility of the victim is paramount. If the victim’s testimony is direct, clear, and positive, it can be sufficient to convict the accused, even in the absence of other corroborating evidence.
What is the penalty for statutory rape in the Philippines?	Under Article 335 of the Revised Penal Code, as amended by R.A. No. 7659, the penalty for statutory rape is reclusion perpetua, which is a term of imprisonment for life.
What is the difference between moral damages and civil indemnity?	Moral damages are awarded to compensate the victim for the emotional distress, suffering, and mental anguish caused by the crime. Civil indemnity, on the other hand, is a separate monetary award that the court orders the accused to pay as compensation for the crime itself.

The Aguiluz case reinforces the principle that children are especially vulnerable and require the full protection of the law. The Court’s decision highlights the importance of safeguarding children from sexual exploitation and ensuring that perpetrators are brought to justice.

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. Florante Aguiluz y Nuque, G.R. No. 133480, March 15, 2001