In the case of People of the Philippines vs. Crisanto Manahan, the Supreme Court affirmed the conviction of Crisanto Manahan for the crime of rape against a minor. The Court emphasized that inconsistencies in minor details do not necessarily undermine the credibility of the victim’s testimony. Furthermore, it held that the defense of impotency must be substantiated by competent medical evidence to overturn the presumption of potency. This decision underscores the importance of protecting vulnerable victims and ensuring that defenses are based on solid factual and medical grounds.

When Silence Speaks: A Step-Grandfather’s Betrayal and a Child’s Delayed Cry for Justice

The case revolves around Crisanto Manahan, who was convicted of raping his step-granddaughter, AAA, who was twelve years old at the time of the incident in September 1997. AAA reported the rape to her teacher in February 1998, leading to a medical examination and the filing of charges. The central issue was whether the inconsistencies in AAA’s testimony and the defense of impotency raised by Crisanto were sufficient to overturn the trial court’s guilty verdict.

At trial, the prosecution presented AAA’s testimony, which detailed how Crisanto threatened her with a knife and then raped her. Dr. Joel Jurado’s medical certificate corroborated the physical fact of the rape, noting healed hymenal lacerations. Crisanto, on the other hand, presented a defense of denial and impotency, arguing that his medical condition made it impossible for him to commit the crime. He also attempted to impeach AAA’s credibility by pointing out inconsistencies between her affidavit and her testimony.

The trial court gave credence to AAA’s testimony, finding it straightforward and sincere. It dismissed the inconsistencies as minor details that did not affect the substance of her declaration. The court also rejected Crisanto’s defense of impotency, noting that he failed to provide sufficient medical evidence to support his claim.

On appeal, Crisanto argued that the trial court erred in convicting him based on the inconsistent testimony of AAA and in not giving weight to his testimony and the testimony of his doctor witness. He also challenged the award of moral damages. The Supreme Court, however, found these arguments unmeritorious.

The Supreme Court emphasized that the credibility of a complainant’s testimony in a rape case rests mainly on the narration of the essential fact of the rape: the carnal knowledge of a woman without her consent. The Court has repeatedly held that minor inconsistencies do not destroy the credibility of a witness. As the trial court noted:

Contradictions in the testimony of the complainant on minor details even tend to strengthen rather than weaken her credibility by erasing any suspicion of a rehearsed testimony.

This principle recognizes that a rehearsed testimony would likely be devoid of such minor inconsistencies, making their presence an indicator of genuine recollection. Furthermore, the Court acknowledged the psychological impact of trauma on a victim’s memory, which can explain slight variations in their recounting of events.

The Court also addressed the issue of delay in reporting the rape incident, noting that the five-month delay was explained by the threat against AAA’s life and the lives of her family members. The Court has consistently held that such a threat is a valid reason for delay and does not affect the complainant’s credibility. In People v. Perez, the Supreme Court explained:

It is difficult to predict, in every instance, how a person, especially a child, reacts to traumatic experiences. What is within the realm of experience is that it is common for a victim of rape to hesitate, for varying periods of time, before reporting the incident. Often, it is because of a real or imagined fear for the victim’s life, or the lives of others, and the natural aversion to exposing the shame that accompanies the experience.

Regarding Crisanto’s defense of impotency, the Court held that it is a physical and medical question that must be satisfactorily established with competent expert testimony. Crisanto presented evidence of his hypertension and the medications he was taking, which, according to Dr. Efren Nerva, could affect his potency. However, Dr. Nerva could not testify as to the actual effects of the medication on Crisanto, and no impotency tests were conducted.

The Court noted that even if tests had been successfully conducted and offered in evidence, the defense of impotency might still fail. In People v. Ablog, the Supreme Court established that proving impotency does not automatically negate the commission of rape:

The fact that the accused is impotent does not necessarily mean that he could not have committed the crime of rape. Impotency is the physical inability to perform the act of sexual intercourse or to procreate. It does not necessarily mean lack of sexual desire.

Therefore, the Court concluded that Crisanto failed to provide sufficient evidence to support his defense of impotency.

Finally, the Court addressed the award of damages. While the lower court awarded P50,000 as moral damages, the Supreme Court modified the judgment to include an additional P50,000 as civil indemnity ex delicto. Civil indemnity is compulsory in rape cases, and its limit for simple rape is set at P50,000.

In summary, the Supreme Court affirmed Crisanto Manahan’s conviction for simple rape, emphasizing the importance of the victim’s testimony and the need for solid evidence to support any defense. The Court’s decision underscores its commitment to protecting vulnerable victims and ensuring justice in rape cases.

FAQs

What was the key issue in this case?	The key issues were the credibility of the minor victim’s testimony despite minor inconsistencies and the validity of the defense of impotency without sufficient medical evidence.
What did the medical examination reveal?	The medical examination conducted by Dr. Joel Jurado revealed healed hymenal lacerations, which were consistent with sexual intercourse. This finding corroborated the victim’s testimony.
Why was there a delay in reporting the incident?	The victim delayed reporting the incident due to threats made by the accused against her life and the lives of her family members. The Court considered this a valid reason for the delay.
What evidence did the accused present to support his claim of impotency?	The accused presented evidence of his hypertension and the medications he was taking, which he claimed could affect his potency. However, he failed to provide conclusive medical evidence to prove his impotency.
What is the significance of minor inconsistencies in the victim’s testimony?	The Court ruled that minor inconsistencies do not necessarily undermine the credibility of the victim’s testimony. In fact, they can strengthen credibility by suggesting the testimony was not rehearsed.
What is the penalty for simple rape under Philippine law?	The penalty for simple rape, as applied in this case, is reclusion perpetua, which is imprisonment for life.
What damages were awarded to the victim?	The victim was awarded P50,000 as moral damages and an additional P50,000 as civil indemnity ex delicto.
Why did the Supreme Court modify the lower court’s decision?	The Supreme Court modified the decision to include civil indemnity ex delicto, which is a compulsory award in rape cases, separate from moral damages.

This case reinforces the legal principles surrounding the prosecution of rape cases in the Philippines, particularly concerning the assessment of victim testimony and the substantiation of defenses. The Supreme Court’s emphasis on protecting vulnerable victims and requiring concrete evidence for defenses serves as a guide for future cases involving similar circumstances.

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 OF THE PHILIPPINES, APPELLEE, VS. CRISANTO MANAHAN Y DOE, APPELLANT., G.R. No. 138924, August 05, 2003