In People v. XYZ, the Supreme Court affirmed the conviction of the accused for the crime of Rape under Article 266-A of the Revised Penal Code. The Court emphasized that the testimony of a child victim is given significant weight, especially when it is consistent and credible. This case underscores the importance of protecting vulnerable individuals and ensuring justice for victims of sexual assault, even in the absence of corroborating physical evidence.

Justice Prevails: The Upholding of a Rape Conviction Based on the Victim’s Account

This case revolves around the charges filed against XYZ for three counts of rape against AAA, a 15-year-old minor. The incidents allegedly occurred in December 2013 and January 2014 in Bulacan. XYZ was the common-law husband of AAA’s sister. The Regional Trial Court (RTC) found XYZ guilty beyond reasonable doubt for the rape committed on December 23, 2013, but acquitted him on the other two charges. The Court of Appeals (CA) affirmed the RTC’s decision with modifications, leading to XYZ’s appeal to the Supreme Court.

The central issue before the Supreme Court was whether the CA correctly affirmed XYZ’s conviction for rape. The defense argued that AAA’s testimony was inconsistent with her affidavit and that the absence of evident injury negated the commission of rape. The prosecution, on the other hand, maintained that AAA’s testimony was credible and sufficient for conviction. The Supreme Court, in its analysis, emphasized the established rule that the trial court is in the best position to assess the credibility of witnesses. The Court also highlighted that findings of fact by the trial court are accorded great respect by appellate courts unless there are glaring errors or misapprehensions of facts.

The Supreme Court underscored the elements of rape under Article 266-A of the Revised Penal Code, which include carnal knowledge of a woman through force, threat, or intimidation. The Court noted that AAA had provided a detailed account of how XYZ had forced himself upon her. Her testimony clearly established the elements of the crime. The Court recognized that inconsistencies cited by the defense were minor and did not detract from the central fact of the rape. In this case, AAA testified under oath that XYZ succeeded in having carnal knowledge of her through force, threat, and intimidation.

Art. 265-A. Rape: When And How Committed. — Rape is committed —
1) By a man who shall have carnal knowledge of a woman under any of the following circumstances:
a) Through force, threat, or intimidation;

The Supreme Court addressed the defense’s argument regarding the absence of fresh hymenal laceration. The Court clarified that hymenal laceration is not an element of rape. The victim’s testimony, if credible, is sufficient to secure a conviction. The Court cited established jurisprudence that a medical examination of the victim is not indispensable when the victim’s testimony is credible.

The Court also addressed the issue of delay in reporting the crime. The Court explained that delay does not necessarily render a charge unworthy of belief. Victims may delay reporting due to fear, shame, or threats from the assailant. The Court found AAA’s explanation for the delay, stemming from XYZ’s threats to evict her family from their home, to be credible. The Court referenced relevant cases to emphasize this point.

Settled is the rule that delay or hesitation in reporting a case of rape due to threats of the assailant is justified and must not be taken against the victim.

Ultimately, the Supreme Court upheld the conviction, reiterating that XYZ’s denial and alibi could not prevail over AAA’s positive and categorical testimony. The Court found no compelling reason to deviate from the factual findings of the RTC and the CA. The penalty of reclusion perpetua and the award of damages were affirmed, in accordance with applicable laws and jurisprudence. The Court held that the crime committed fell squarely under Article 266-A of the Revised Penal Code, as amended by Republic Act No. 8353.

In examining this case, the importance of credible witness testimony, especially from victims of sexual assault, cannot be overstated. Courts will scrutinize inconsistencies in testimonies but also recognize that minor discrepancies can occur, particularly when a child recounts a traumatic event. The absence of physical evidence, such as hymenal laceration, is not a bar to conviction if the victim’s testimony is convincing. The principles regarding delay in reporting a crime provide essential safeguards for victims who may face threats or other impediments to reporting immediately.

What was the key issue in this case?	The key issue was whether the Court of Appeals correctly affirmed the accused’s conviction for rape, based primarily on the testimony of the victim.
What are the elements of rape under Article 266-A of the Revised Penal Code?	The elements are: (1) the offender had carnal knowledge of a woman, and (2) such act was accomplished through force, threat, or intimidation.
Is a medical examination necessary for a rape conviction?	No, a medical examination is not indispensable. The victim’s credible testimony alone is sufficient to convict.
Does delay in reporting a rape incident affect the credibility of the victim?	Not necessarily. Delay can be justified due to fear, shame, or threats from the assailant, and is not automatically taken against the victim.
What is the penalty for rape under Article 266-A?	The penalty for rape under paragraph 1 of Article 266-A is reclusion perpetua.
What damages can be awarded to the victim in a rape case?	The victim can be awarded civil indemnity, moral damages, and exemplary damages.
What weight is given to a child victim’s testimony?	Testimonies of child victims are given full weight and credit, especially when a girl-child says that she has been raped.
Can an accused be convicted of rape based solely on the victim’s testimony?	Yes, an accused can be convicted based solely on the victim’s testimony, provided that the testimony is credible and convincing.

This decision reinforces the protection afforded to vulnerable individuals under the law, emphasizing that credible testimony from victims of sexual assault can be sufficient for conviction, even in the absence of corroborating physical evidence. The Supreme Court’s affirmation of the accused’s guilt underscores the importance of listening to and believing survivors of sexual violence.

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 vs. XYZ, G.R. No. 246975, March 23, 2022