In The People of the Philippines v. Decoroso Aca-ac y Cespon, the Supreme Court affirmed the conviction of the accused for statutory rape. The Court clarified that even slight penetration of the female genitalia constitutes consummated rape, especially when the victim is a minor. This decision underscores the judiciary’s commitment to protecting children and reinforces the principle that lack of physical injury does not negate the crime of rape.

A Cousin’s Betrayal: Can a Child’s Testimony Overcome Claims of Impossibility?

This case revolves around the accusations of Fritzie Aca-ac, a minor, against her relative, Decoroso Aca-ac. Fritzie accused Decoroso of four separate instances of rape. The Regional Trial Court (RTC) initially convicted Decoroso of frustrated rape in one instance, but acquitted him on the other charges. The RTC’s decision hinged on the absence of lacerations in Fritzie’s hymen. Upon appeal, the Court of Appeals (CA) modified the ruling, finding Decoroso guilty of consummated rape and sentencing him to reclusion perpetua. This discrepancy in findings prompted a review by the Supreme Court, focusing on the nature of the crime and the credibility of the witnesses.

The Supreme Court addressed the RTC’s error in categorizing the crime as “frustrated rape.” Quoting People v. Orita, the Court reiterated that rape is either attempted or consummated, with no frustrated stage:

Clearly, in the crime of rape, from the moment the offender has carnal knowledge of his victim, he actually attains his purpose and, from that moment also all the essential elements of the offense have been accomplished. Nothing more is left to be done by the offender, because he has performed the last act necessary to produce the crime.

The Court emphasized that any penetration, however slight, of the female genitalia by the male organ is sufficient for consummation. The absence of a broken hymen or lacerations does not negate the crime. This is a crucial point, as it removes the misconception that physical injury is a prerequisite for proving rape. Decoroso’s defense rested partly on his age and alleged inability to achieve an erection. The Court dismissed this claim as self-serving, stating that age is not a definitive factor in determining sexual interest or potency.

Building on this principle, the Court scrutinized the credibility of Fritzie’s testimony. Decoroso argued that her detailed account was indicative of someone worldly and experienced, not a child. The Court rejected this argument, emphasizing that a victim’s willingness to undergo the trauma of a trial is strong evidence of the abuse suffered. The Court noted:

For no woman would allow an examination of her private parts or go through the humiliation of a trial unless she has actually been so brutalized that she desires justice for her suffering.

In cases of statutory rape, where the victim is a minor, the law places a high burden on the accused, and the child’s testimony is given significant weight. The court found no reason to doubt Fritzie’s testimony, especially considering her age and the threats she received, which explained her initial silence.

The testimony of Algerico Lonio, a classmate of Fritzie, further corroborated her account. Lonio claimed to have witnessed the rape. Decoroso challenged Lonio’s credibility, citing his failure to immediately report the incident and alleged inconsistencies in his testimony. However, the Court found Lonio’s testimony to be credible, emphasizing that he revealed the incident to Fritzie’s mother out of concern and fear of the accused. The court found:

It was evident that Lonio was telling the truth. He cried after narrating to the court how he told his mother about the incident. When the trial judge asked him why he cried,  Lonio said that he was hurt because the same thing happened to his younger sister. He also said that he kept his silence in the beginning because he feared for his life.

The Court addressed the issue of damages awarded to Fritzie. While the Court of Appeals affirmed the trial court’s award of moral damages (P30,000.00) and exemplary damages (P20,000.00), the Supreme Court modified this ruling. Citing current jurisprudence, the Court increased the moral damages to P50,000.00 and awarded P50,000.00 as civil indemnity. However, the exemplary damages were deleted due to a lack of specific basis.

The Supreme Court’s decision reinforced the definition of consummated rape, particularly in cases involving minors. It underscored that even the slightest penetration is sufficient for conviction, and the absence of physical injury does not negate the crime. The Court also emphasized the importance of giving credence to the testimony of child victims, especially when corroborated by other evidence.

FAQs

What is the definition of consummated rape according to this case?	Consummated rape occurs with even the slightest penetration of the female genitalia by the male organ. The absence of a broken hymen or lacerations does not negate the crime.
Why was the accused initially convicted of frustrated rape?	The Regional Trial Court initially based its decision on the absence of lacerations in the victim’s hymen, leading to the incorrect classification of the crime as frustrated rape.
What did the Supreme Court say about the credibility of the victim’s testimony?	The Supreme Court emphasized that the victim’s willingness to undergo the trauma of a trial is strong evidence of the abuse suffered. The Court found no reason to doubt the child victim’s testimony.
How did the Court address the argument that the accused was too old to commit the crime?	The Court dismissed the argument that the accused’s age made it impossible for him to commit the crime, stating that age is not a definitive factor in determining sexual interest or potency.
What role did the testimony of the witness Algerico Lonio play in the case?	Lonio’s testimony corroborated the victim’s account. Despite challenges to his credibility, the Court found his testimony believable and consistent with the victim’s statements.
What were the damages awarded to the victim, and how were they modified by the Supreme Court?	The Court increased the moral damages to P50,000.00 and awarded P50,000.00 as civil indemnity. The exemplary damages were deleted due to a lack of specific basis.
What is statutory rape, and why was it relevant in this case?	Statutory rape refers to sexual intercourse with a minor, regardless of consent. It was relevant in this case because the victim was 11 years old at the time of the incident.
What is the practical implication of this decision for victims of rape?	This decision reinforces the protection of child victims and underscores that any form of penetration constitutes consummated rape. It also emphasizes the importance of giving credence to the testimony of child victims.

In conclusion, the Supreme Court’s decision in People v. Aca-ac serves as a crucial reminder of the law’s commitment to protecting vulnerable members of society, especially children. The ruling clarifies the definition of consummated rape, reinforces the credibility of child victims, and sends a clear message that perpetrators of sexual abuse will be held accountable.

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. Aca-ac, G.R. No. 142500, April 20, 2001