Case Digest (G.R. No. 178323)
Facts:
On March 19, 2005, the People of the Philippines filed an Information in the City of Manila charging Armando Chingh y Parcia with rape for inserting his fingers and later his penis into the vagina of ten‑year‑old VVV on March 11, 2004; Armando pleaded not guilty and trial ensued.
The Regional Trial Court convicted him of Statutory Rape and sentenced him to reclusion perpetua with damages; the Court of Appeals affirmed and additionally convicted him of Rape Through Sexual Assault, imposed an indeterminate sentence for the second count and awarded aggregate damages, prompting this appeal to the Supreme Court.
Issues:
- Did the trial court err in convicting the accused of rape under Article 266‑A(1)(d) despite alleged inconsistencies in the victim’s testimony?
- Did the prosecution prove the accused guilty beyond reasonable doubt?
Ruling:
The Court affirmed the conviction on both counts but modified the penalty for the second count. The Court affirmed the conviction for Statutory Rape and the imposition of reclusion perpetua. For Rape Through Sexual Assault, the Court imposed the indeterminate penalty of twelve years, ten months and twenty‑one days to fifteen years, six months and twenty days of reclusion temporal. The Court also affirmed and adjusted the damages awarded to the victim.
Ratio:
The Court found the victim’s testimony credible and corroborated by the medical report showing a fresh hymenal laceration and bleeding consistent with penetrating trauma within twenty‑four hours of examination, and by positive identification at lineup; the victim’s age was established as ten years. The Court held that a credible lone testimony of the victim sufficed to sustain conviction, that bare denial and alibi were inherently weak, and that because the Information charged two offenses and the accused failed to move to quash, the court could convict of as many offenses as were charged and proved under Section 3, Rule 120, Rules of Court. Applying R.A. No. 7610, the Court concluded that the act of inserting a finger into the genital of a child under twelve constituted lascivious conduct attracting the penalty under that statute and, under the Indeterminate Sentence Law, adjusted the proper minimum and maximum terms for the second count.
Doctrine:
- The credible testimony of a child victim, if corroborated, is sufficient to sustain a rape conviction.
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