The Supreme Court affirmed the conviction of Ernie P. Carillo and Ronald L. Espique for the crime of rape, emphasizing the importance of the victim’s testimony and the lack of clear-cut behavior expected from rape victims. The Court underscored that minor inconsistencies in the victim’s statements do not detract from her credibility, especially when her testimony is coherent and intrinsically believable. This case serves as a stern reminder that inconsistencies will not necessarily free a guilty person.

Justice for AAA: When Unconsciousness Becomes the Defining Element in a Rape Case

The case of People of the Philippines vs. Ernie Carillo y Pabello stems from an incident on October 6, 2006, in Las Piñas City, where AAA, a nursing student, was abducted and subsequently raped. Initially, Ernie Carillo, Ronald Espique, and Rafael Susada were charged with rape under Article 266-A paragraph 1 of the Revised Penal Code (RPC), which penalizes the carnal knowledge of a woman who is unconscious. The Regional Trial Court (RTC) found Carillo, Espique, and Susada guilty beyond reasonable doubt for two counts of rape. The Court of Appeals (CA) affirmed the RTC’s decision regarding Carillo and Espique but acquitted Susada due to lack of evidence, modifying the conviction to a single count of rape since they were only charged with one count in the information.

Article 266-A 1(b) of the Revised Penal Code, as amended, is central to the case. It defines rape as committed by a man who has carnal knowledge of a woman when she is deprived of reason or is otherwise unconscious. The Supreme Court emphasized that the evidence presented sufficiently established the elements of rape under this provision. AAA testified that she lost consciousness after being abducted, and upon regaining it, she was sexually assaulted by Carillo and Espique. This state of unconsciousness, coupled with the sexual acts perpetrated by the accused, satisfied the requisites of Article 266-A(1)(b) of the RPC.

In assessing the credibility of the victim’s testimony, the Court addressed the defense’s argument regarding inconsistencies between AAA’s testimony and her complaint-affidavit. The defense pointed out that AAA stated she lost consciousness immediately after being abducted, but also testified to seeing the perpetrators and being awake during the assault. The Supreme Court dismissed this argument, citing the principle established in People v. Burce, which holds that trial courts are in the best position to assess the credibility of witnesses due to their opportunity to observe their demeanor and deportment on the stand. The Court reiterated that minor discrepancies do not affect the veracity or credibility of a witness’s testimony as long as it is coherent and intrinsically believable as a whole, as established in People v. Corpuz.

As a general rule, on the question whether to believe the version of the prosecution or that of the defense, the trial court’s choice is generally viewed as correct and entitled to the highest respect because it is more competent to conclude so, having had the opportunity to observe the witnesses’ demeanor and deportment on the witness stand as they gave their testimonies.

The Court also addressed the argument that AAA’s actions following the incident—confiding in classmates and friends rather than her family—were contrary to human experience. The Court acknowledged that there is no clear-cut behavior expected of a rape victim, and failure to seek help or report the incident immediately does not negate the commission of rape. As stated in People v. Pareja, failure of the victim to shout or seek help does not negate rape. The Court further noted that many victims prefer to bear the ignominy and pain rather than reveal their shame, citing People v. Ogarte.

The defense of alibi presented by Carillo and Espique was also discredited by the Court. Alibi is considered an inherently weak defense, as it is easy to fabricate and difficult to verify. In order to be given weight, the accused must present clear and convincing evidence that they were in a different place at the time the crime was committed, making it physically impossible for them to be at the scene. In this case, Carillo and Espique failed to provide such evidence, thus their alibi did not stand against the prosecution’s evidence.

The Supreme Court affirmed the penalty of reclusion perpetua imposed by the lower courts, in accordance with Article 266-B of the RPC. However, the Court modified the amount of damages awarded to AAA, aligning it with prevailing jurisprudence, particularly the case of People v. Jugueta. The Court awarded Php 75,000.00 as civil indemnity, Php 75,000.00 as moral damages, and Php 75,000.00 as exemplary damages, recognizing the inherent bestiality of the act committed.

The imposition of exemplary damages in rape cases highlights the Court’s recognition of the extreme depravity and moral injury inflicted upon the victim. Even without specific aggravating circumstances, the inherent nature of rape warrants the imposition of exemplary damages as a form of retribution and as a deterrent against similar acts. Furthermore, the Court ordered that all damages awarded shall earn legal interest at the rate of six percent (6%) per annum from the date of finality of judgment until fully paid, in line with People v. Sabal.

This case reinforces several key principles in Philippine jurisprudence concerning rape cases. First, it underscores the importance of the victim’s testimony as a primary form of evidence. Second, it recognizes that inconsistencies do not automatically negate the victim’s credibility, especially when the testimony is coherent and intrinsically believable. Third, it acknowledges the varied and unpredictable reactions of rape victims, rejecting the notion that a victim must exhibit specific behaviors to be believed. Finally, it emphasizes the weakness of alibi as a defense, requiring concrete and convincing evidence to support it.

FAQs

What was the key issue in this case?	The key issue was whether the prosecution successfully proved beyond reasonable doubt that Ernie Carillo and Ronald Espique committed rape, particularly focusing on the victim’s state of unconsciousness and the credibility of her testimony.
What is Article 266-A of the Revised Penal Code?	Article 266-A defines the crime of rape and outlines the circumstances under which it is committed, including when the victim is deprived of reason or is otherwise unconscious.
Why was Rafael Susada acquitted?	Rafael Susada was acquitted because the prosecution failed to provide sufficient evidence linking him to the crime, and the victim testified that she did not see him at the scene of the incident.
What is the significance of the victim’s unconsciousness in this case?	The victim’s unconsciousness was a critical element, as it satisfied the requirements of Article 266-A(1)(b) of the RPC, which defines rape as occurring when the victim is deprived of reason or is otherwise unconscious.
What is reclusion perpetua?	Reclusion perpetua is a penalty under the Revised Penal Code, which imprisons a person for at least twenty years and one day and can extend to a lifetime imprisonment, depending on the specific provisions of the law and the court’s decision.
How did the Court address the inconsistencies in the victim’s testimony?	The Court addressed the inconsistencies by stating that minor discrepancies do not affect the veracity or credibility of a witness’s testimony as long as it is coherent and intrinsically believable as a whole.
Why was the defense of alibi rejected by the Court?	The defense of alibi was rejected because the accused failed to provide clear and convincing evidence that they were in a different place at the time the crime was committed, making it physically impossible for them to be at the scene.
What damages were awarded to the victim in this case?	The victim was awarded Php 75,000.00 as civil indemnity, Php 75,000.00 as moral damages, and Php 75,000.00 as exemplary damages, with all damages earning legal interest at the rate of six percent (6%) per annum from the date of finality of judgment until fully paid.

This case highlights the crucial role of the victim’s testimony and the legal standards applied in rape cases, particularly those involving unconscious victims. The Supreme Court’s decision underscores the importance of a thorough examination of all evidence while protecting the rights and dignity of the victim.

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. Carillo, G.R. No. 212814, July 12, 2017