Case Digest (G.R. No. 212161)
Facts:
People of the Philippines v. Juanito Entrampas, G.R. No. 212161, March 29, 2017, Supreme Court Second Division, Leonen, J., writing for the Court. The case concerns appeals from convictions for two counts of statutory rape after an 11-year-old girl, hereinafter AAA, became pregnant and later gave birth following repeated sexual assaults allegedly committed by Juanito Entrampas (the accused), the common-law husband and household partner of AAA’s mother, BBB.AAA lived with BBB and Entrampas in Barangay Bawod, San Isidro, Leyte. The assaults began in February 2003 when, on returning from school, AAA was summoned by Entrampas to a room and was twice raped in the course of that month and repeatedly thereafter. Entrampas threatened to kill AAA and her mother if she reported the incidents and a knife was present within his reach; AAA cried and pleaded but did not shout or immediately report the assault out of fear. Over months AAA’s body showed signs of pregnancy; a pregnancy test administered in September 2003 was positive, and she delivered a baby boy on November 3, 2003.
Criminal informations for two separate counts of rape were filed in the Regional Trial Court (RTC), charging Entrampas with statutory rape under the Revised Penal Code as amended by Republic Act No. 8353. The prosecution presented AAA’s birth certificate, the pregnancy laboratory report, a medical certification, and testimonies from BBB, AAA, the Municipal Health Officer (Dr. Danilo Bagaporo), and CCC (to whom Entrampas allegedly confessed). Entrampas testified in his defense, denying the assaults, asserting alibis, and contesting alleged inconsistencies in AAA’s testimony and the late registration of her birth certificate (registered July 9, 2002).
On December 6, 2008, the RTC (Branch 11, Calubian, Leyte) convicted Entrampas of two counts of statutory rape and sentenced him to reclusion perpetua in each case, awarding civil indemnity and moral damages (dispositives in the RTC Decision are reproduced in the record). The Court of Appeals (Twentieth Division), in a Decision penned by Associate Justice Ramon Paul L. Hernando dated November 6, 2013, affirmed the RTC conviction but increased the award of civil indemnity and moral damages to Php75,000 each and imposed Php30,000 as exemplary damages with interest. On December 2, 2013, Entrampa...(Subscriber-Only)
Issues:
- Do the alleged inconsistencies and collateral discrepancies in the minor victim’s testimony undermine her credibility so as to vitiate the conviction?
- Was the birth certificate’s late registration sufficient to rebut the presumption that AAA was under twelve years of age at the time of the first assault?
- On the whole evidence, is Entrampas guilty beyond reasonable doubt of two counts of statutory rape, with the qualifying circumstance that he was the common-law...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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