G.R. No. 183577 - People vs. Escoton

The case involves appellant Hilario Escoton, charged with multiple counts of rape against his 10-year-old niece, designated as “AAA.”
The case was prosecuted by the People of the Philippines, with the trial rendered by the Regional Trial Court (RTC) of Carigara, Leyte, Branch 13, and subsequently affirmed with modifications by the Court of Appeals (CA).
The decision was reached on February 1, 2010 (G.R. No. 183577), with the appellate court ultimately affirming the conviction.

The Information alleged that on May 12, 2001, at around 7 o’clock in the evening in a locale within Leyte, the appellant, driven by deliberate intent and lewd designs, raped “AAA”—his niece—on five separate occasions in one evening.
The crime was characterized by the use of force, intimidation, and a sickle as a weapon, with the qualifying circumstance of the victim being under 18 years of age and the offender being a relative by consanguinity within the third civil degree.
Evidence presented included documentary proofs such as the Certificate of Live Birth and Baptismal Certificate of “AAA,” establishing her age, and a medical examination report revealing incomplete healed lacerations of the hymen at several positions.

The victim testified that on the night in question, she was asleep along with her brother at their grandmother’s house when the appellant woke her up and took her to his house approximately 500 meters away.
Upon reaching the appellant’s residence, he undressed himself and removed “AAA’s” lower garments before forcibly inserting his penis into her vagina.
“AAA” recounted that despite her pleas for him to stop, he raped her five times throughout the night.
Her immediate report to her grandmother and the subsequent medical examination, despite the later unavailability of the examining doctors, served to strengthen her account, with the Records Officer attesting to the authenticity of the medico-legal report.

The appellant presented a conflicting version, alleging that he was returning home after drinking tuba, and that he had only fetched “AAA” upon request, later pushing her after she disobeyed his instruction to go home.
He contended that “AAA” fabricated the accusation following an argument with his family and as retribution for prior disciplinary actions.
The defense claimed that inconsistencies in “AAA’s” narrative cast doubt on her credibility and asserted that her allegations were motivated by revenge or family feuds.

The RTC rendered a decision on June 28, 2004, convicting the appellant beyond reasonable doubt for the crime of multiple rape and sentencing him to death, alongside awarding civil indemnity, moral, and exemplary damages to “AAA.”
The Court of Appeals, while modifying certain aspects of the RTC’s decision, affirmed the conviction and imposed the penalty of reclusion perpetua (in place of the death sentence due to Republic Act No. 9346) for each of the five counts of rape committed.
In addition to the prison term, the CA ordered the appellant to pay specified amounts for civil indemnity, moral damages, and exemplary damages for each count.

Whether “AAA’s” testimony, despite minor inconsistencies, could be accorded full credence given the circumstances of a traumatic and humiliating event.
Whether the trial court’s determination, based solely on her account, was sufficient to establish the appellant’s guilt beyond reasonable doubt in a rape case.

The issue of the weight to be given to the medical report, whose authenticity was confirmed despite the absence of the examining physicians during trial.
Whether the absence of corroborating witnesses for the defense’s version undermines the reliability of the appellant’s account.

Whether the minor discrepancies in “AAA’s” narrative affected the adjudication of the crime, given the gravity of the act and the circumstances under which her evidence was given.
The extent to which these inconsistencies are expected in a case involving a child victim recounting a harrowing experience.

Whether the imposition of the death penalty as provided under Article 266-B was appropriate, and how Republic Act No. 9346 affected the sentencing.
The propriety of awarding the specified amounts in damages for each count of rape under prevailing jurisprudence.