G.R. No. L-2869 - Carino vs. The Insular Government

The accused-appellant, Melecio de los Santos, Jr., was charged with two counts of statutory rape in Criminal Case Nos. CBU-51855 and CBU-51856.
The offenses allegedly occurred against the minor victim, referred to as AAA, who was below 12 years of age at the time of the first incident.
The accused-appellant is identified as the younger brother of the victim’s mother, complicating the familial relationship.
During the pre-trial conference, the parties stipulated that the accused and AAA’s mother are siblings, and the defense maintained a denial of the charges.

AAA testified that on that day, while she and her younger sister BBB were at their house, the accused-appellant appeared at the window.
AAA recounted that after her mother instructed BBB to leave for work, she was left alone with the accused.
The accused-appellant allegedly closed the windows and door, retrieved a knife from the kitchen, and ordered her to undress.
Upon her refusal, he forcibly tore off her dress and had carnal knowledge of her with the continued threat of using the knife to kill her family if she reported the incident.
Medical evidence, including a certificate from Dr. Plaza and physical findings of “deep, hymenal notches at 3 o’clock and 9 o’clock positions,” was presented to corroborate the victim’s account.

AAA testified that during a separate incident when her family was absent, the accused-appellant again undressed her and, using similar threats, raped her.
The testimony regarding this second incident was found to be insufficient and lacking in detailed corroboration as compared to the first incident.

The prosecution presented multiple documents, including the birth certificate of AAA, a sworn statement, a medical certificate, a police blotter certification, and a letter confirming her examination at a hospital.
Key testimonies were given by:

Victim AAA, who detailed the events of both incidents.
BBB, the younger sister, who confirmed her observations during the first incident.
CCC, the victim’s father, who testified on learning about the rape and his subsequent actions.
Dr. Plaza, who explained the medical findings that supported the victim’s claim of sexual abuse.
Police Officer Rea N. Taladua, who verified procedural elements and the victim’s complaint.

The accused-appellant’s own testimony was aimed at negating the prosecution’s account by providing an alibi, asserting his presence in another location on the day of the alleged incident, and emphasizing his adoption and limited connection with the victim’s family.
The defense also presented documents such as the death certificate of the accused’s adoptive father and his marriage certificate to support his version of events.

At arraignment, the accused-appellant pleaded not guilty to the statutory rape charges.
The Regional Trial Court (RTC) conducted a joint trial on both cases.
In Criminal Case No. CBU-51855, the RTC found the accused-appellant guilty beyond reasonable doubt of rape and sentenced him to reclusion perpetua, along with imposing civil indemnity, moral damages, and exemplary damages.
In Criminal Case No. CBU-51856, the RTC acquitted him due to the insufficiency and lack of detail in the testimony regarding the second incident.
The RTC’s decision was later affirmed by the Court of Appeals, which upheld the conviction for the first incident while noting that minor discrepancies in witness testimonies did not affect the overall credibility of the prosecution’s evidence.

The accused-appellant raised issues on appeal, asserting that the trial court committed errors in convicting him beyond reasonable doubt and overly relying on the prosecution’s evidence, despite his denial and alibi.
The Court of Appeals and subsequently the Supreme Court reviewed the record, focusing on the credibility of victim testimonies and supporting medical evidence.
The appellate courts found that the prosecution had sufficiently established the elements of statutory rape, especially given the victim’s age and the corroborative nature of the evidence.

Whether the trial court erred in convicting the accused-appellant of rape beyond reasonable doubt based solely on the testimony and evidence presented by the prosecution.
Whether the trial court improperly gave full credence to the prosecution’s evidence, particularly considering the discrepancies in the testimonies of AAA and BBB regarding minor details.
Whether the accused-appellant’s defense of denial, centered on his alibi and conflicting evidence, was properly considered given the lack of corroborative support.
Whether the presentation and subsequent admission of AAA’s birth certificate, despite minor discrepancies in the name, was appropriate and correctly validated the victim’s age.
Whether the overall evidence was sufficient to establish that AAA was below twelve years of age at the time of the sexual abuse, thereby satisfying the element of statutory rape.