In People of the Philippines v. Jonathan “Uto” Veloso y Rama, the Supreme Court affirmed the conviction of the accused for two counts of rape against a 12-year-old minor, emphasizing the great weight given to the trial court’s assessment of the victim’s credibility. This decision reinforces the protection afforded to children under the law and underscores that inconsistencies in a minor’s testimony do not automatically undermine her credibility. It also clarifies the basis for awarding exemplary damages in such heinous crimes, ensuring that the offender is adequately punished and that the victim receives just compensation for the harm suffered.

From Water Lilies to Justice: Examining Testimony and Responsibility in a Rape Case

The case began with the filing of two informations against Jonathan “Uto” Veloso y Rama, accusing him of raping AAA, a 12-year-old girl, on April 4, 2002, in Naga City. The prosecution presented testimonies from neighbors, medical professionals, and the victim’s mother to build their case. According to the prosecution, Veloso lured AAA away from her home under the pretense of visiting her uncle, only to assault her near a riverbank. The defense, led solely by Veloso himself, presented an alibi, claiming he was at a birthday party in a different town at the time of the incident.

The Regional Trial Court (RTC) found Veloso guilty beyond reasonable doubt of rape in both cases, sentencing him to reclusion perpetua for each count. The RTC also ordered Veloso to pay the victim moral damages, civil indemnity, and exemplary damages. On appeal, the Court of Appeals affirmed the RTC’s findings but deleted the award of exemplary damages. Veloso then appealed to the Supreme Court, arguing that the victim’s testimony was improbable and inconsistent, and that the prosecution had not proven his guilt beyond a reasonable doubt.

The Supreme Court emphasized the principle of affording great respect to the trial court’s assessment of the credibility of witnesses. The Court highlighted that the trial judge directly observes the demeanor and body language of the witnesses, which enables them to better determine the truthfulness of their testimonies. In cases of rape, where witnesses are often scarce, the victim’s credibility becomes paramount.

“Unless certain facts of substance and value were overlooked which, if considered, might affect the result of the case, its assessment must be respected for it had the opportunity to observe the conduct and demeanor of the witnesses while testifying and detect if they were lying. The rule finds an even more stringent application where said findings are sustained by the [Court of Appeals].” (Citation omitted, emphasis added.)

The Court addressed the appellant’s argument that the victim’s testimony was improbable, specifically regarding the alleged rape on water lilies. The Court clarified that the victim testified that she was made to lie down on the riverbank covered with grass and water lilies, not on water lilies floating on the river. This distinction addressed the appellant’s claim that the water lilies could not have supported their combined weights.

Furthermore, the Supreme Court considered the victim’s attempts to resist the appellant’s advances. Despite being only 12 years old, she tried to kick and stave off the attack. The Court acknowledged that the appellant, a 25-year-old man, overpowered her. This recognition aligns with the established principle that the law does not impose a burden on the rape victim to prove resistance; instead, the prosecution must prove the use of force or intimidation.

“In a litany of cases, this Court has ruled that the testimonies of child-victims of rape are to be given full weight and credence. Reason and experience dictate that a girl of tender years, who barely understands sex and sexuality, is unlikely to impute to any man a crime so serious as rape, if what she claims is not true.” (Citation omitted, emphasis added.)

The Court also scrutinized the appellant’s alibi, noting its inherent weakness. To be considered valid, an alibi must be supported by clear and convincing evidence that the accused was in a different location at the time of the crime, making it physically impossible for them to have been present at the scene. Veloso’s alibi lacked corroboration. He failed to present his cousin to support his claim of being at a birthday party. Additionally, he admitted to visiting the victim’s residence on the morning of the incident.

Regarding the Court of Appeals’ deletion of exemplary damages, the Supreme Court disagreed, reinstating the RTC’s award. The Court referenced Article 2229 of the Civil Code, emphasizing that exemplary damages serve as a deterrent to serious wrongdoings and a vindication of undue sufferings. The Court noted that exemplary damages could be awarded in cases of highly reprehensible or outrageous conduct, even without an aggravating circumstance.

“Being corrective in nature, exemplary damages, therefore, can be awarded, not only in the presence of an aggravating circumstance, but also where the circumstances of the case show the highly reprehensible or outrageous conduct of the offender. In much the same way as Article 2230 prescribes an instance when exemplary damages may be awarded, Article 2229, the main provision, lays down the very basis of the award.”

The Court pointed out that in similar cases involving sexual abuse of minors, exemplary damages were awarded to set a public example and deter elders from abusing and corrupting the youth. Consequently, the Supreme Court reinstated the RTC’s award of exemplary damages, setting it at P30,000.00 for each count of rape. Additionally, the Court imposed a legal interest rate of 6% per annum on all monetary awards, from the date of finality of the decision until fully paid.

FAQs

What was the key issue in this case?	The central issue was whether the accused was guilty beyond reasonable doubt of raping a 12-year-old girl, and whether the award of exemplary damages was proper. The Supreme Court examined the credibility of the victim’s testimony and the circumstances surrounding the crime.
What is the penalty for rape under Article 266-A of the Revised Penal Code?	Article 266-A of the Revised Penal Code defines rape, and Article 266-B provides the penalties, which can include reclusion perpetua depending on the circumstances. The penalty is more severe when the victim is a minor or when the crime is committed with aggravating circumstances.
Why is the credibility of the victim so important in rape cases?	Rape is often a crime committed in private with no other witnesses. Therefore, the victim’s testimony is often the primary source of evidence, making her credibility essential to the case.
What constitutes a valid alibi in a criminal case?	For an alibi to be valid, the accused must prove they were in a different location at the time of the crime, making it physically impossible for them to have committed the offense. The alibi must be supported by credible evidence and not just the accused’s testimony.
What are exemplary damages?	Exemplary damages are awarded to serve as a deterrent to serious wrongdoings and a vindication of undue sufferings. They punish the offender for outrageous conduct and set a public example.
What is the legal basis for awarding exemplary damages?	Article 2229 of the Civil Code lays the very basis for awarding exemplary damages to deter wrongdoings. These are awarded in cases of gross negligence, or those circumstances that intensifies the injury.
What is the significance of the victim’s age in this case?	The victim’s age (12 years old) is critical because, under the law, sexual intercourse with a minor is considered rape even without force or intimidation. The vulnerability of the victim also warrants a stricter application of the law and the imposition of penalties.
What was the outcome of the appeal to the Supreme Court?	The Supreme Court dismissed the appeal and affirmed the Court of Appeals’ decision with modification. The Supreme Court reinstated the exemplary damages of Php 30,000.00.

This case underscores the importance of protecting vulnerable members of society, especially children, from sexual abuse. The Supreme Court’s decision reinforces the principle that the testimony of a child-victim should be given full weight and credence, and that exemplary damages are warranted in cases of outrageous conduct.

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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. Veloso, G.R. No. 188849, February 13, 2013