The Supreme Court affirmed the rape conviction of Edgar Trayco, emphasizing the protection of children under twelve years of age. This case highlights that sexual intercourse with a minor below this age constitutes statutory rape, regardless of force or consent. The ruling underscores the judiciary’s commitment to safeguarding the most vulnerable members of society, ensuring perpetrators are held accountable under the full extent of the law.

Garage of Grievances: How a Child’s Testimony Secured Justice

In 1998, in Antipolo City, Edgar Trayco was accused of raping AAA, an 11-year-old girl, while armed with a bladed weapon. The prosecution presented AAA’s compelling testimony, supported by medical evidence, which detailed the harrowing ordeal. AAA recounted how Trayco led her to a garage where the assault occurred. The testimony explained in detail acts committed, establishing the basis for the charges, including both physical contact and oral contact.

This testimony included that Trayco approached her with a sharp object, and this induced fear, culminating in the sexual offenses within the garage. This crucial detail was further corroborated by the medico-legal report, which confirmed the recent loss of virginity and fresh hymenal lacerations. The defendant countered this with an alibi. Trayco claimed to have been working at the time of the incident, delivering water with his employer. The Regional Trial Court found Trayco guilty, a verdict subsequently upheld by the Court of Appeals. However, Trayco continued to assert his innocence, appealing to the Supreme Court, where he argued the prosecution failed to prove his guilt beyond a reasonable doubt.

The Supreme Court ultimately denied the appeal, affirming the lower courts’ decisions. The Supreme Court examined key elements defining rape under Article 266-A of the Revised Penal Code, as amended by Republic Act No. 8353. The court highlighted that for a rape conviction, the prosecution must demonstrate that the accused engaged in carnal knowledge with a woman, achieved through force, threat, or intimidation. Alternatively, if the victim is under twelve years old, the element of consent is irrelevant. This principle reflects statutory rape.

AAA’s testimony, considered clear, convincing, and credible, was critical. The Supreme Court focused on the absence of any evidence that would cause doubt in AAA’s narrative. This was deemed to be especially critical given that the young rape victims’ testimony, due to their innocence, deserve full credence. Moreover, there was no doubt since they are highly unlikely to invent such claims. This Court has consistently asserted that no young woman would fabricate a story of defloration. Further, if they had not been motivated by the pursuit of justice for the wrong committed against her she would not subject herself to the invasive process.

The court also found the appellant’s defenses of denial and alibi unconvincing. Trayco’s alibi was undermined by inconsistencies in his testimony regarding his whereabouts during the time of the rape. The appellant tried to invoke a discrepancy in time between him leaving for his employer, however, this only hurt him as it only stressed that he was not certain when he arrived and left from locations. Furthermore, the court noted it was not impossible for the appellant to have been in the area during that period due to being in close proximity. Thus, since it was not physical impossibility he failed to meet the exception to the rule.

Therefore, because she was an 11 year-old girl, at the time of the rape. Trayco’s conviction was just. Under this article, even without threat, violence, or intimidation, as long as there is penetration of the vagina the individual is to be charged for the actions. The Court then reinforced that the applicable penalty for rape under the circumstances dictated is reclusion perpetua.

To provide further remedy the Court discussed compensation and restitution. Consistent with current legal standards, in addition to reclusion perpetua, the Court affirmed a mandatory civil indemnity of P50,000 and moral damages also of P50,000 as per the prior ruling. Furthermore, to fully restore the individual victimized, the Court determined exemplary damages in the amount of P30,000 would further punish and dissuade others from committing this act against vulnerable individuals. These additional damages help to prevent others from committing the crime in the first place.

FAQs

What was the key issue in this case?	The key issue was whether Edgar Trayco was guilty of raping AAA, an 11-year-old girl, and whether the prosecution had sufficiently proven his guilt beyond a reasonable doubt. The court also examined what damages would be made available to the victim, and ultimately decided on civil indemnity, moral damages, and examplary damages.
What is statutory rape?	Statutory rape refers to sexual intercourse with a person who is under the legal age of consent, regardless of whether force or consent was involved. In this case, because AAA was 11 years old, any sexual contact with her constitutes statutory rape.
What evidence did the prosecution present?	The prosecution presented AAA’s testimony detailing the assault, as well as a medico-legal report confirming the recent loss of virginity and fresh hymenal lacerations. Also a certificate and testimony was given to support that the individual was underage, at the time of the attack.
What was the appellant’s defense?	The appellant’s defense was based on denial and alibi. Trayco claimed he was working at the time of the incident, delivering water with his employer, however, that did not meet the evidentiary threshold.
How did the Court assess AAA’s testimony?	The Court found AAA’s testimony to be clear, convincing, and credible, noting the absence of any evidence that would suggest she had ulterior motives or was fabricating her story. The Court emphasized because she was a minor she should receive full creedance to her story.
What is the significance of the victim’s age in this case?	Since AAA was under 12 years of age, the element of force, threat, or intimidation was not necessary to establish the crime of rape; the law presumes the absence of consent in cases involving children under this age. The primary focus shifted from consent to age of the victim and establishing that carnal knowledge took place.
What penalties did the Court impose?	The Court affirmed the penalty of reclusion perpetua and ordered Trayco to pay the victim P50,000 as civil indemnity, P50,000 as moral damages, and P30,000 as exemplary damages. These additional damages further help and compensate the vulnerable victim.
What are exemplary damages and why were they awarded?	Exemplary damages are awarded as a form of punishment and to serve as a deterrent to others who might consider similar actions. The court made that the payment of these will reinforce their belief against the elder against abusing and corrupting youths.

The Supreme Court’s decision in People v. Trayco serves as a firm warning against those who prey on children, affirming the judiciary’s role in protecting the most vulnerable. This ruling underscores the importance of child testimony, highlights the court’s perspective on alibis, and further illustrates different factors on punishments to ensure an appropriate outcome. These conclusions and guidance help others and is a signal to future perpetrators who think about doing such acts.

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, PLAINTIFF-APPELLEE, VS. EDGAR TRAYCO Y MASOLA, ACCUSED-APPELLANT, G.R. No. 171313, August 16, 2009