In People v. Regalado, the Supreme Court affirmed the conviction of Eddie Regalado for three counts of statutory rape, emphasizing the law’s protective stance towards children. The Court reiterated that in cases of statutory rape involving victims under twelve years of age, the element of consent is irrelevant because the law presumes the child’s incapacity to give valid consent. This ruling underscores the state’s commitment to safeguarding children from sexual abuse, ensuring that perpetrators are held accountable for their actions.

Childhood Betrayed: Justice for Statutory Rape Victims in Iriga City

The case revolves around the repeated sexual abuse of a 10-year-old girl, AAA, by Eddie Regalado in Iriga City. The incidents occurred in 2007, with AAA testifying that Regalado would lure her to a pansitan (a small eatery) in the public market, where he would undress and rape her. Despite the public location, AAA stated that the market was deserted during the weekdays when the abuse took place. Out of fear, AAA initially kept the assaults secret, but eventually confided in her teacher, leading to Regalado’s arrest and subsequent trial.

The Regional Trial Court (RTC) found Regalado guilty of three counts of statutory rape, and the Court of Appeals (CA) affirmed this decision. Regalado appealed to the Supreme Court, arguing that the prosecution failed to prove his guilt beyond a reasonable doubt. He presented an alibi, claiming he was working at a piggery during the time of the offenses. He also attempted to discredit AAA’s testimony by presenting a witness who claimed that the pansitan where the rapes allegedly occurred was actually a parlor that was only open on Sundays. Despite these defenses, the Supreme Court upheld the lower courts’ rulings.

At the heart of the Supreme Court’s decision lies the legal definition and elements of **statutory rape** as defined under Articles 266-A and 266-B of the Revised Penal Code, as amended by R.A. No. 8353. These provisions state:

Art. 266-A. Rape: When and How Committed. – Rape is committed:

1) by a man who shall have carnal knowledge of a woman xxx:

xxxx

d) when the offended party is under twelve (12) years of age or is demented, even though none of the circumstances mentioned above be present.

Art. 266-B. Penalty. – Rape under paragraph 1 of the next preceding article shall be punished by reclusion perpetua.

The Court emphasized that to secure a conviction for statutory rape, the prosecution must prove two key elements: the victim’s age (under 12 years old) and the offender’s carnal knowledge of the victim. The Supreme Court cited the Court of Appeals’ apt summation of these points, stating:

“xxx, neither the use of force, threat or intimidation on the female, nor the female’s deprivation of reason or being otherwise unconscious, nor the employment on the female of fraudulent machinations or grave abuse of authority is necessary to commit statutory rape. Further, the absence of free consent is conclusively presumed when the victim is below the age of twelve (12). At that age, the law presumes that the victim does not possess discernment and is incapable of giving intelligent consent to the sexual act.”

Building on this principle, the Court highlighted that the prosecution successfully demonstrated these elements through AAA’s birth certificate, which established her age, and her credible testimony regarding the sexual acts committed by Regalado. The Court found AAA’s testimony to be positive and categorical, warranting full weight and credence. Her identification of Regalado in open court as the perpetrator further solidified the prosecution’s case.

The Court also addressed Regalado’s defenses of denial and alibi, dismissing them as inherently weak. For an alibi to be given weight, the accused must demonstrate that it was physically impossible for him to be at the scene of the crime at the time of its commission. Regalado failed to provide sufficient evidence to support his alibi or to discredit AAA’s testimony.

The Supreme Court also addressed the defense’s attempt to discredit AAA’s testimony by presenting a witness who contradicted her description of the crime scene. The Court deemed these inconsistencies as trivial, noting that minor discrepancies in a witness’s testimony do not necessarily undermine their credibility. The Court emphasized that ample margin of error and understanding must be accorded to young witnesses, who are often gripped with tension when testifying in court. In such cases, the positive identification of the accused as the assailant remains the crucial factor.

Finally, the Supreme Court addressed the damages awarded to AAA, increasing the amount of exemplary damages to P75,000.00 for each count of rape, in line with recent jurisprudence. AAA was also awarded civil indemnity of P75,000.00 for each count of rape and moral damages of P75,000.00 for each count of rape.

The decision underscores the gravity of statutory rape and the importance of protecting children from sexual abuse. It also reinforces the principle that the testimony of child victims should be given full weight and credence, especially when it is consistent and credible. This case serves as a reminder that perpetrators of sexual abuse against children will be held accountable for their actions, and that the courts will not hesitate to impose the full force of the law to protect the vulnerable.

FAQs

What is statutory rape?	Statutory rape is defined as sexual intercourse with a minor, specifically someone under the age of 12, as outlined in the Revised Penal Code. In these cases, consent is irrelevant due to the child’s presumed inability to give it.
What are the key elements the prosecution must prove in a statutory rape case?	The prosecution must prove two key elements: the age of the victim (under 12 years old) and that the accused had carnal knowledge of the victim. Establishing these elements beyond a reasonable doubt is crucial for a conviction.
Why is the victim’s consent not a factor in statutory rape cases involving children under 12?	The law presumes that children under 12 lack the capacity to understand the nature of the sexual act and therefore cannot give valid consent. This presumption protects children from exploitation and abuse.
What is the significance of a positive identification by the victim in a statutory rape case?	A positive and credible identification by the victim is a critical piece of evidence in a statutory rape case. Courts often give significant weight to the testimony of child victims, recognizing their vulnerability and the trauma they have experienced.
What are the penalties for statutory rape in the Philippines?	Under the Revised Penal Code, as amended, statutory rape is punishable by reclusion perpetua, which is imprisonment for life. Additionally, the offender may be required to pay damages to the victim.
How does the court view alibi as a defense in statutory rape cases?	Alibi is considered a weak defense unless the accused can prove that it was physically impossible for them to be at the scene of the crime. The defense must present credible evidence to support their claim of being elsewhere when the crime occurred.
What types of damages can be awarded to a victim of statutory rape?	Victims of statutory rape may be awarded civil indemnity, moral damages, and exemplary damages. These damages are intended to compensate the victim for the harm they have suffered and to deter future offenses.
How does the court handle inconsistencies in a child’s testimony in statutory rape cases?	Minor inconsistencies in a child’s testimony are often excused, considering the trauma they have experienced and the challenges of recalling events accurately. The focus remains on the overall credibility and consistency of the child’s account.
What role do expert witnesses play in statutory rape cases?	Expert witnesses, such as medical professionals, may provide testimony about physical evidence or the psychological impact of the abuse on the victim. Their testimony can help the court understand complex issues related to the case.

The People v. Regalado case highlights the unwavering commitment of the Philippine legal system to protect children from sexual abuse. The Supreme Court’s decision reinforces the importance of holding perpetrators accountable and ensuring that victims receive the justice and support they deserve. Moving forward, this ruling will continue to serve as a guiding precedent in similar cases, strengthening the protection of children under the law.

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 v. Regalado, G.R. No. 210752, August 17, 2016