In People of the Philippines v. Antonio Lujeco, the Supreme Court affirmed the conviction of the accused for statutory rape, emphasizing the importance of protecting children and upholding their rights in the justice system. This case underscores the court’s unwavering stance against sexual abuse of minors, reinforcing the principle that the testimony of a child victim, when credible and consistent, is sufficient to establish guilt beyond reasonable doubt. The decision also illustrates how the courts balance the rights of the accused with the need to safeguard vulnerable members of society, ensuring that perpetrators of such heinous crimes are brought to justice.

The Unwavering Voice of a Child: Justice Prevails in Statutory Rape Case

The case originated from an incident on June 29, 2002, in Don Carlos, Bukidnon, where Antonio Lujeco, also known as “Tonyo,” was accused of raping a seven-year-old girl, referred to as “AAA” to protect her identity. The Regional Trial Court (RTC) of Malaybalay, Branch 8, found Lujeco guilty of statutory rape after considering the evidence presented. The prosecution established that Lujeco grabbed “AAA” while she was playing near her house, dragged her to a nearby house, and forcibly had carnal knowledge of her. This decision was later affirmed by the Court of Appeals (CA). Undeterred, Lujeco appealed to the Supreme Court, questioning the credibility of the victim’s testimony. His defense centered on the claim that “AAA” was influenced by her mother during her testimony.

The Supreme Court, however, found no merit in Lujeco’s arguments. The Court emphasized that “AAA” was only seven years old at the time of the assault and eight when she testified. The trial judge had even inquired if “AAA” needed a support person, to which the prosecution suggested her mother, without objection from the defense. The Supreme Court noted that the mother’s presence, embracing her daughter during the testimony, did not constitute coaching. Furthermore, the Court found that “AAA’s” testimony was categorical and straightforward, even at her young age. She unequivocally identified Lujeco as the rapist. The trial court had also observed “AAA’s” intelligence and perceptiveness, noting that her demeanor as a witness enhanced her credibility and trustworthiness. The victim’s candid account of the incident was deemed convincing.

The Supreme Court highlighted the significance of a child’s testimony in cases of this nature. The Court recognized the inherent vulnerability of young victims and the unlikelihood of a child fabricating such a traumatic experience. It noted that courts are inclined to lend credence to the testimonies of young, immature girls, especially considering the shame and embarrassment they would endure if their testimony were untrue. The Court of Appeals echoed this sentiment, stating:

Based on AAA’s testimony, it is clear that the appellant had carnal knowledge of the victim who was under twelve (12) years old. AAA categorically recounted the details of how appellant raped her by pushing hard to insert his penis into her labia majora. She was only seven (7) years old when she was raped. It is improbable that a victim of tender years, especially one unexposed to the ways of the world as AAA must have been, would impute a crime as serious as rape if it were not true. There is no doubt that AAA was impelled solely by a desire to let justice find its way.

Moreover, “AAA’s” testimony was corroborated by medical findings. Dr. Marichu Macias testified that “AAA” suffered fresh hymenal lacerations and showed signs of sexual molestation injury, with contusion-hematoma found on both sides of her labia majora. This medical evidence supported the victim’s account, strengthening the prosecution’s case. The defense attempted to explain the contusions as potentially caused by riding a bike, but the Court rejected this argument, reaffirming that “AAA” testified that Lujeco had inserted his penis into her vagina and pushed it hard.

Lujeco also presented an alibi, claiming he was at the public market of Don Carlos when the crime occurred. However, the Court dismissed this defense as inherently weak, particularly in light of the positive identification by the victim. The Court emphasized that for an alibi to be credible, it must be proven that it was physically impossible for the accused to be present at the crime scene. The fact that Lujeco was at the public market did not preclude his presence at the crime scene. The Court of Appeals articulated this point clearly:

It has been held, time and again, that alibi, as a defense, is inherently weak and crumbles in light of positive identification by truthful witnesses. It should be noted that for alibi to prosper, it is not enough for the accused to prove that he was in another place when the crime was committed. He must likewise prove that it was physically impossible for him to be present at the crime scene or its immediate vicinity at the time of its commission.

The Supreme Court affirmed Lujeco’s conviction for statutory rape under Article 266-A of the Revised Penal Code. This article defines rape as the carnal knowledge of a woman under twelve years of age, regardless of the circumstances. The elements of the crime were clearly established in this case: Lujeco had carnal knowledge of “AAA,” and “AAA” was below twelve years old. The court then addressed the penalty and damages awarded by the lower courts. The original sentence of reclusion perpetua was upheld, but modifications were made to the damages awarded. While the accused in this case was found guilty of statutory rape, the Supreme Court has stated that persons convicted of offenses punished with reclusion perpetua are not eligible for parole under Act No. 4180.

The Supreme Court reduced the civil indemnity and moral damages from P75,000.00 each to P50,000.00 each, aligning the awards with prevailing jurisprudence. The award of actual damages in the amount of P25,000.00 was deleted due to a lack of evidentiary basis. However, the Court awarded exemplary damages of P30,000.00 to “AAA.” Additionally, the Court ordered that all damages awarded would earn legal interest at a rate of 6% per annum from the date of finality of the Resolution until fully paid. These adjustments reflect the Court’s commitment to providing just compensation to the victim while adhering to established legal principles.

FAQs

What was the key issue in this case?	The key issue was whether the accused, Antonio Lujeco, was guilty beyond reasonable doubt of statutory rape against a seven-year-old girl. The Supreme Court assessed the credibility of the victim’s testimony and the validity of the defense’s arguments.
What is statutory rape under Philippine law?	Statutory rape, as defined under Article 266-A of the Revised Penal Code, involves carnal knowledge of a woman under twelve years of age, regardless of whether force, threat, or intimidation is present. The law emphasizes the vulnerability of the victim due to her age.
Why did the Supreme Court give credence to the victim’s testimony?	The Supreme Court found the victim’s testimony to be categorical, straightforward, and credible, especially considering her young age. The Court noted that it is improbable for a child to fabricate such a traumatic experience, further supported by medical evidence.
What was the significance of the medical findings in this case?	The medical findings, particularly the fresh hymenal lacerations and contusion-hematoma on the victim’s labia majora, corroborated her testimony. This evidence supported the prosecution’s claim that sexual molestation had occurred.
Why was the accused’s alibi rejected by the Court?	The accused’s alibi was rejected because he failed to prove that it was physically impossible for him to be present at the crime scene. His presence at the public market did not preclude his ability to commit the crime.
What is the penalty for statutory rape under the Revised Penal Code?	Under Article 266-B of the Revised Penal Code, as amended, the penalty for statutory rape is reclusion perpetua, which is imprisonment for life. In this case, the accused was sentenced to reclusion perpetua.
What modifications were made to the damages awarded?	The Supreme Court reduced the civil indemnity and moral damages from P75,000.00 each to P50,000.00 each. The award of actual damages was deleted, and exemplary damages of P30,000.00 were awarded to the victim.
Are individuals convicted of statutory rape eligible for parole?	No, pursuant to Section 3 of Republic Act No. 9346, individuals convicted of offenses punishable by reclusion perpetua, such as statutory rape, are not eligible for parole.

The Supreme Court’s decision in this case reinforces the importance of protecting children from sexual abuse and ensuring that perpetrators are held accountable. The Court’s careful consideration of the evidence and the victim’s testimony underscores the commitment of the Philippine legal system to safeguarding the rights and welfare of its most vulnerable members.

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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 v. Lujeco, G.R. No. 198059, April 07, 2014