G.R. No. 241249 - People vs. Fetalco y Sablay

Case Digest (G.R. No. 241249)
Expanded Legal Reasoning Model

Facts:

Charge and Information

In an Information dated February 24, 2006, appellant Ryan Fetalco y Sablay was charged with rape—specifically statutory rape—alleging that he committed carnal knowledge upon AAA, a girl who was only four (4) years old at the time.
The Information alleged that on or about July 17, 2005, within the jurisdiction of xxxxxxx City, the accused, with a lewd design and by means of force and intimidation, unlawfully and feloniously had sexual intercourse with the minor, an act which debased, degraded, and demeaned a child’s intrinsic dignity.

Testimonies and Evidence Presented by the Prosecution

Three key witnesses testified:

Private complainant AAA, a four-year-old at the time of the incident.
Complainant's mother, BBB, who corroborated details of the incident.
Medico-Legal Officer Dr. Ruby Grace Sabino-Dingson, who presented forensic evidence.

AAA’s Statements:

On July 23, 2005 (six days after the incident), AAA executed a sworn statement (Sinumpaang Salaysay) wherein she described the act by stating that the appellant inserted his hairy male organ—referred to as a “daga” (rat)—into her vagina.
At later testimonies, including in 2008 and during cross-examination in 2010, AAA’s account varied slightly, at one point mentioning that a fishball stick was inserted, and also changing the reported location of the incident from the house of the appellant to that of her own.

BBB’s Testimony:

BBB testified that she was present in the household when the incident occurred and corroborated AAA’s description of the object inserted (“daga” resembling a rat).

Medico-Legal Evidence:

Dr. Sabino-Dingson presented the original Medico Legal Report showing that AAA’s hymen had shallow, healed lacerations at the 9 o’clock position, an indication of penetrating trauma.
The medical findings were deemed consistent with the physical evidence of a sexual assault as described by AAA.

Defense’s Presentation and Testimony

The appellant denied all charges, testifying that on July 17, 2005, he was at his brother’s house engaged in cleaning and later had lunch there.
He contended that the accusation was motivated by a dispute over unpaid rentals by AAA’s family.
The defense relied on his denial and assertive alibi, though without corroborative evidence or witnesses to substantiate his claims.

Procedural History and Decisions

Regional Trial Court (RTC):

On May 18, 2016, the RTC of xxxxxxx City, Branch 169, rendered a Decision convicting the appellant of statutory rape beyond reasonable doubt.
The RTC credited the credibility of the child witness despite noted discrepancies, emphasizing her young age and the inherent difficulties in recalling traumatic events.
The RTC ruled that the medico-legal report, which showed clear evidence of penetrating trauma, substantiated the victim’s account, and ultimately dismissed the appellant’s denial and alibi.
The sentence imposed was reclusion perpetua without eligibility for parole along with orders to pay civil indemnity, moral damages, and exemplary damages.

Court of Appeals (CA):

On February 28, 2018, the CA affirmed, with modifications, the RTC’s Decision—upholding the conviction for statutory rape.
The CA adjusted the monetary awards (later further modified in the Supreme Court ruling), while reiterating that the elements of statutory rape were met based on the evidence.
The CA dismissed the appellant’s contention regarding discrepancies in AAA's testimony and rebutted the claim concerning the hearsay nature of the medico-legal report.

Issues Raised on Appeal

The appellant raised multiple issues:

That the trial court erred in giving full credence to the inconsistent statements of the child witness AAA and her mother BBB.
That the prosecution failed to prove rape by sexual intercourse as alleged in the Information.
That the absence of the medico-legal officer in court diminished the probative value of the medical report.
That the defenses of denial and alibi were not properly considered.

Supreme Court Resolution

The Supreme Court, led by Justice Peralta, dismissed the appellant’s appeal.
The Court affirmed the findings of both the RTC and the CA, holding that the prosecution had proven every element of statutory rape beyond reasonable doubt.
The decision modified the damage awards, increasing them to P100,000.00 each for civil indemnity, moral, and exemplary damages, and ordered the payment of interest accruing at 6% per annum.
The Court reiterated the inherent deference due to the trial court in assessing the credibility of witness testimony, especially from vulnerable, traumatized child victims.

Issues:

Credibility of the Victim’s Testimony

Whether the inconsistencies in AAA’s accounts—such as the differing descriptions of the object inserted and the location of the incident—were substantial enough to undermine her overall credibility.

Sufficiency of Evidence to Prove Statutory Rape

Whether the prosecution’s evidence, particularly the victim’s testimony and the corroborative medico-legal report, sufficiently established that statutory rape, as charged, had been committed.

Admissibility and Probative Value of the Medico-Legal Report

Whether the absence of the medico-legal officer (the preparer of the report) in court undermined the admissibility or reliability of the medico-legal evidence presented.

Weight Given to the Defendant’s Alibi and Denial

Whether the trial court erred in discounting the appellant’s defenses of denial and alibi in light of the overall evidence presented.

Ruling:

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Ratio:

(Subscriber-Only)

Doctrine:

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Case Digest (G.R. No. 241249) Core Legal Reasoning Model Expanded

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Case Digest (G.R. No. 241249) Expanded Legal Reasoning Model

Facts:

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Doctrine:

Case Digest (G.R. No. 241249)
Core Legal Reasoning Model

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Case Digest (G.R. No. 241249)
Expanded Legal Reasoning Model