G.R. No. 238176 - People vs. Bay-od

The case originates from a criminal information filed on April 11, 2014, against appellant Ramon Bay-od for qualified statutory rape under Article 266-A(1)(d), qualified by item 5 of the fifth paragraph of Article 266-B of the Revised Penal Code as amended.
The charge stemmed from allegations that in 2011, Bay-od unlawfully and feloniously had carnal knowledge of AAA, a minor who was only six (6) years old at that time.
The incident allegedly occurred at CCC within the jurisdiction of the Regional Trial Court (RTC) of Lagawe, Ifugao, and was later docketed as Criminal Case No. 2224.

During the pre-trial conference, both the prosecution and defense stipulated to the fact that AAA was six years old in 2011, the year of the alleged rape.
The prosecution presented its case by primarily relying on the testimonies of:

The minor victim, AAA, who recounted in detail the events of the crime.
BBB, AAA’s mother, who confirmed elements of the victim’s testimony upon an incident of family confrontation.

Additional evidence was provided by Dr. Florilyn Joyce Bentrez, the medical officer who performed a physical examination on AAA on November 15, 2013, and issued a medical certificate noting the absence of lacerations, hematoma, and bleeding in the victim’s genital area.
Despite the noted absence of physical injuries, Dr. Bentrez explained that the condition of the hymen may vary and that rape could occur even if the victim’s hymen remained intact.

On July 1, 2016, the RTC found Ramon Bay-od guilty beyond reasonable doubt of qualified statutory rape.
The RTC accorded full weight and credence to the testimonies of AAA and BBB and noted that, given the nature of the crime, Bay-od could have been sentenced to death; however, due to Republic Act No. 9346 outlawing the imposition of the death penalty, the penalty of reclusion perpetua without eligibility for parole was imposed instead.
Additionally, the RTC ordered the appellant to pay civil indemnity, moral damages, exemplary damages, and interest to the victim AAA.

The appellant filed an appeal with the Court of Appeals (CA), which on October 20, 2017, affirmed in toto the RTC’s decision and dismissed Bay-od’s appeal.
Despite the CA’s affirmation, Bay-od subsequently elevated the issue to the Supreme Court, contesting the full weight given to AAA’s testimony, particularly in light of the medical evidence presented by Dr. Bentrez.

The appellant argued that the RTC and the CA erred in giving full credibility to AAA’s testimony, asserting that the evidence of an intact hymen observed by Dr. Bentrez should negate the claim of rape.
Bay-od contended that the charge was fabricated by AAA’s family, accusing them of acting out of envy and attempting to wrongfully implicate him.
The Supreme Court, however, maintained that the evaluation of witness credibility—especially that of a minor—falls within the exclusive competence of the trial court, whose assessment should only be disturbed under exceptional and compelling circumstances.

Whether the absence of physical injury (specifically, an intact hymen as noted in the medical examination) is sufficient to disprove the claim of rape against the appellant.
Whether the appellate courts erred in giving full weight and credence to the testimony of a six-year-old victim despite conflicting medical findings.
Whether the appellant’s argument that the victim’s account was fabricated by envious family members constitutes a valid ground for overturning the trial court’s findings.