In People v. Dandito Lastrollo, the Supreme Court affirmed the conviction of Dandito Lastrollo for rape, emphasizing the weight given to the victim’s credible testimony, even in the absence of corroborating evidence. The Court reiterated that the victim’s straightforward and consistent account, coupled with the accused’s weak defense of alibi, was sufficient to establish guilt beyond reasonable doubt. This decision reinforces the principle that a victim’s testimony, if deemed truthful and consistent, can be the cornerstone of a rape conviction, highlighting the importance of the trial court’s assessment of witness credibility.

When Silence Speaks Volumes: Overcoming Fear in Rape Cases

This case revolves around the harrowing experience of AAA, a minor with a mental disability, who accused her uncle, Dandito Lastrollo, of rape. The incidents allegedly occurred in November and December 2003 in Barangay CCC, Nabua, Camarines Sur. Dandito was charged with rape under Article 335 of the Revised Penal Code, as amended. The central legal question is whether the testimony of the victim, AAA, who has mental disabilities, is sufficient to prove Dandito’s guilt beyond reasonable doubt, especially when considering his defense of alibi and denial.

At trial, AAA recounted two instances of rape, detailing how Dandito threatened her with a bolo and warned her not to disclose the assaults. Her mother, BBB, testified about AAA’s mental condition and the discovery of her pregnancy. Dr. Gilda Gonzales confirmed AAA’s pregnancy and estimated that the sexual contact occurred around November or December 2003. In contrast, Dandito presented an alibi, claiming he was working as a fish gatherer in Bato Lake during the relevant period, supported by his wife and employer. This alibi was meant to prove it was impossible for him to be at the crime scene. The Regional Trial Court (RTC) found Dandito guilty, giving weight to AAA’s testimony and discrediting the alibi. The Court of Appeals (CA) affirmed this decision, further emphasizing the credibility of AAA’s account.

The Supreme Court (SC) focused on the credibility of the victim’s testimony. The SC has repeatedly stressed the unique position of the trial court in directly observing the demeanor of witnesses. This allows them to determine their truthfulness. Absent any substantial reason to reverse the RTC’s evaluation, the reviewing court is generally bound by the lower court’s findings. This principle is even more stringently applied when the CA concurs with the RTC’s assessment.

The Court underscored the positive and categorical nature of AAA’s testimony. Despite her cognitive limitations, she clearly articulated the sexual abuse inflicted upon her by Dandito through force and threats. The CA further affirmed that AAA’s testimony was straightforward and steadfast, even under cross-examination. The Court also addressed Dandito’s argument that AAA’s account lacked specific details about the sexual positions and her feelings during the intercourse. The Court referenced People v. Saludo, which emphasizes that rape victims often do not remember specific details due to the traumatic nature of the experience.

Rape is a painful experience which is oftentimes not remembered in detail. For such an offense is not analogous to a person’s achievement or accomplishment as to be worth recalling or reliving; rather, it is something which causes deep psychological wounds and casts a stigma upon the victim, scarring her psyche for life and which her conscious and subconscious mind would opt to forget. Thus, a rape victim cannot be expected to mechanically keep and then give an accurate account of the traumatic and horrifying experience she had undergone.

The SC also rejected the argument that AAA’s delayed reporting of the incident cast doubt on her credibility. The Court highlighted that there is no single established reaction to rape. Victims’ actions are often driven by fear, especially when threatened by the perpetrator. This delay is justified because the perpetrator builds a climate of extreme psychological terror, effectively silencing the victim. AAA’s silence was therefore understandable, given Dandito’s threats and their familial relationship.

Turning to Dandito’s defense of alibi, the Court reiterated the requirements for a successful alibi defense. An accused must prove (a) presence at another place at the time of the crime and (b) physical impossibility to be at the crime scene. Physical impossibility relates to the distance and accessibility between the accused’s location and the crime scene. The Court found that Dandito failed to prove it was physically impossible for him to be at AAA’s residence during the rape incidents. By his own admission, the distance between his workplace and AAA’s house could be traversed within an hour by bicycle or less by motorized vehicle.

Moreover, Dandito testified that he would return home once a month, further undermining his alibi. Consequently, the SC affirmed the established principle that denial and alibi are inherently weak defenses that cannot prevail over the positive and credible testimony of the prosecution witness. The Court then addressed the imposable penalty and the award of damages.

Article 266-B of the Revised Penal Code dictates the punishment for simple rape as reclusion perpetua. However, the death penalty is imposed if the victim is under eighteen years of age, and the offender is a relative within the third civil degree. In this case, while Dandito is AAA’s uncle, the Information failed to specifically allege that they were relatives within the third civil degree of affinity. This omission is critical because such circumstances must be explicitly stated in the information; otherwise, the death penalty cannot be imposed.

The Court also noted the lack of evidence regarding AAA’s age at the time of the incident. While the Information alleged her minority, the prosecution did not present AAA’s birth certificate or any authentic document showing her birth date. The Court cited People v. Buado, Jr., reiterating guidelines for proving age, emphasizing that the best evidence is a birth certificate or similar authentic documents. Because these qualifying circumstances of minority and third-degree relationship were not duly established, the RTC and CA correctly convicted Dandito of simple rape and imposed reclusion perpetua.

Regarding damages, the Court modified the CA’s award based on People v. Jugueta, awarding AAA P75,000 as civil indemnity, P75,000 as moral damages, and P75,000 as exemplary damages. These damages aim to compensate the victim for the harm suffered and deter similar conduct in the future. All damages awarded accrue interest at 6% per annum from the finality of the judgment until fully paid.

FAQs

What was the key issue in this case?	The key issue was whether the victim’s testimony, despite her mental disability and the lack of corroborating evidence, was sufficient to convict the accused of rape. The Supreme Court affirmed that a credible and consistent testimony is enough for conviction.
What is reclusion perpetua?	Reclusion perpetua is a penalty under the Revised Penal Code, which is a term of imprisonment for life, typically ranging from 20 years and one day to 40 years. The duration depends on the specific provisions of the law and any additional penalties imposed.
What is the significance of the victim’s mental disability in this case?	The victim’s mental disability made her testimony particularly vulnerable to scrutiny. The courts had to carefully assess her credibility and ensure she understood the questions and the implications of her statements, despite the challenges posed by her condition.
Why was the accused’s alibi rejected?	The accused’s alibi was rejected because he failed to prove it was physically impossible for him to be at the crime scene during the commission of the rape. His own testimony indicated that the distance between his workplace and the victim’s home was easily traversable.
What is the evidentiary value of delay in reporting the crime?	Delay in reporting a crime, especially in rape cases, does not automatically discredit the victim’s testimony. The courts recognize that victims may delay reporting due to fear, shame, or psychological trauma. Only unreasonable and unexplained delay can cast doubt on the victim’s credibility.
What are civil indemnity, moral damages, and exemplary damages?	Civil indemnity is compensation for the loss or damage suffered by the victim as a result of the crime. Moral damages are awarded to compensate for mental anguish, emotional distress, and suffering. Exemplary damages are imposed to deter similar conduct and serve as a warning to others.
What is the third civil degree of affinity?	The third civil degree of affinity refers to the relationship between a person and the relatives of his or her spouse. In this case, it would refer to the specific familial relationship between the accused and the victim.
What did the Supreme Court modify in the Court of Appeals’ decision?	The Supreme Court modified the award of damages, increasing the amounts for civil indemnity, moral damages, and exemplary damages to P75,000 each, aligning with the guidelines set in People v. Jugueta.

This case emphasizes the critical role of a victim’s testimony in prosecuting rape cases, especially when coupled with a weak defense. The Supreme Court’s decision underscores the importance of assessing witness credibility and awarding appropriate damages to victims of sexual assault.

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. Lastrollo, G.R. No. 212631, November 7, 2016