G.R. No. 94008 - People vs. Ferdez

The case involves an appeal by Edgar B. Fernandez from the Regional Trial Court’s decision (October 17, 1989) convicting him of the rape of a seven (7) year old child, Marites C. Soriano.
The convicting decision sentenced him to suffer Reclusion Perpetua, ordered him to indemnify the victim P20,000.00, and assessed costs.

On March 8, 1985, around noontime, Marites Soriano, a Grade I student walking home from the Padilla Elementary School in Lingayen, Pangasinan, was accosted.
Edgar B. Fernandez, then a sixteen (16) year old boy, approached her offering two cashew fruits and led her toward the Colegio of Pangasinan Sur.
At a cemented dike near the said location, the accused forced the child to lie down and committed the act of rape by forcing carnal knowledge on her without her consent.
The victim, in distress—bleeding and crying—returned home and promptly reported the incident to her parents.

Marites underwent an embarrassing yet essential medical examination at Sto. Nino Hospital in Lingayen, after which she was transferred by her father to the Pangasinan Provincial Hospital at Dagupan City; a medical report confirmed sexual abuse.
The incident was reported to the police by her father, Eduardo Soriano.
Barangay authorities interviewed a Danny Miranda, a helper residing near the area where the incident took place. His blood-smeared garments were later examined by the NBI and found positive for human blood; however, Marites did not identify him as the perpetrator.

On March 23, 1985, during a basketball game in the public plaza of Lingayen, Marites confidently pointed out the accused as her assailant to her father.
A subsequent police line-up further reinforced her identification of Edgar B. Fernandez as the rapist.
The identification by a seven-year-old, without any indication of confusion or external pressure, played a central role in establishing the accused’s guilt.

The accused’s defense was based on denial and the claim of an alibi, suggesting that Danny Miranda was the true culprit given the circumstances of Miranda’s proximity to the crime and his possession of blood-smeared clothing.
The defense’s alibi was critically examined; school records confirmed the accused’s presence in school on March 8, 1985 but failed to exclude his presence at the scene of the crime.
The court underscored that the child’s unequivocal identification, coupled with the absence of any motive for false testimony, negated the defense’s rationalizations.

The appellant invoked his minority status as a mitigating circumstance. At the time of the offense, he was sixteen (16) years, three (3) months, and twenty-four (24) days old.
Under Article 68, paragraph 2 of the Revised Penal Code, this circumstance entitled him to the imposition of a penalty “next lower than” that prescribed by law for rape.
As a result, although rape under normal circumstances is punishable by reclusion perpetua—a single, indivisible penalty—the mitigating circumstance warranted a reduction to reclusion temporal.

The decision modified the penalty imposed on the accused-appellant, reducing the maximum sentence from reclusion perpetua to reclusion temporal (medium period: 14 years, 8 months, and 1 day; minimum period set at the minimum prision mayor equivalent to 6 years and 1 day).
The conviction was affirmed on the basis that the guilt of the accused was established beyond reasonable doubt, with testimony from an unimpeachable victim and corroborative medical and investigative evidence.

Whether the unequivocal identification by Marites, a seven-year-old child, is sufficiently reliable to establish the accused’s guilt.
Whether the child’s testimony, given her age and the traumatic nature of the incident, could have been mistaken or influenced.

Whether the accused-provided alibi of being in school at the time of the incident is credible and conclusively exonerates him from being at the scene of the crime.
Whether the identification of Danny Miranda as the potential culprit has any substantive evidentiary foundation relative to the accused’s direct involvement.

Whether the appellant’s minority (being under eighteen but over fifteen years old) qualifies as a privileged mitigating circumstance under the law.
Whether the imposition of a reduced penalty (reclusion temporal) in lieu of reclusion perpetua was proper under Article 68 of the Revised Penal Code and relevant jurisprudence.

Whether the totality of the evidence—including physical evidence, medical reports, eyewitness identification, and investigative records—is sufficient to sustain the conviction despite the defense’s claims.