Facts:

The case involves Rodolfo Lopez as the appellant and the People of the Philippines as the appellee. The events leading to the case began on June 11, 1998, when AAA, the mother of the victim BBB, left her home in Barangay XXX, Camarines Norte, to collect credit, leaving her four-year-old daughter BBB in the care of Rodolfo Lopez, an employee of her husband. The following day, AAA took BBB to a manghihilot due to a fever and stomachache. During this visit, BBB requested her mother to wash her vagina, which led AAA to notice that BBB's private organ was swollen and had a small amount of blood. On June 13, 1998, despite still being ill, BBB insisted on taking a bath, during which AAA observed that her vagina remained swollen. When questioned, BBB pointed to Rodolfo Lopez and stated, "It was Kuya Aswang," indicating that he had assaulted her.

AAA confronted BBB about whether Lopez had inserted his penis into her vagina, to which BBB affirmed. BBB recounted that Lo...

Facts:

1. Incident Details:

   • On June 11, 1998, around 5:00 PM, AAA left her house to collect credit, leaving her 4-year-old daughter, BBB, and appellant Rodolfo Lopez, an employee of her husband, at home.
   • The next day, June 12, 1998, BBB complained of a fever and stomachache. AAA brought her to a manghihilot (traditional healer). While washing BBB’s vagina, AAA noticed swelling and a small amount of blood, initially assuming it was due to an accidental bump.
   • On June 13, 1998, BBB revealed that appellant Lopez had sexually assaulted her, stating, "It was Kuya Aswang," and described how he removed her underwear, placed himself on top of her, and inserted his penis into her vagina.

2. Medical Examination:

   • On June 15, 1998, BBB was examined by Dr. Marcelito B. Abas, who found a superficial hymenal laceration at the 9 o’clock position, consistent with penetration by an erect penis.

3. Legal Proceedings:

   • An Information was filed on July 17, 1998, charging appellant Lopez with Statutory Rape under Article 335 of the Revised Penal Code, as amended by RA 8353.
   • During the trial, the prosecution presented testimonies from AAA, BBB, and Dr. Abas, along with other witnesses. The defense relied solely on appellant Lopez’s testimony, where he denied the allegations and instead accused BBB’s 6-year-old brother of inserting his finger into her vagina.

4. Trial Court Decision:

   • The Regional Trial Court (RTC) found appellant Lopez guilty beyond reasonable doubt and sentenced him to death. The case was appealed to the Court of Appeals (CA) due to the imposition of the death penalty.

5. Court of Appeals Decision:

   • The CA affirmed the RTC’s decision but modified the penalty to reclusion perpetua, in accordance with RA 9346, which prohibits the death penalty.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Elements of Statutory Rape:

   • Under Article 335 of the Revised Penal Code, as amended by RA 8353, statutory rape is committed when:
     a) The offender has carnal knowledge of a woman; and
     b) The woman is under 12 years of age.
   • Force, intimidation, or lack of consent is immaterial in statutory rape, as the law presumes that a child below 12 cannot give valid consent.

2. Credibility of the Victim’s Testimony:

   • The testimony of BBB, the 4-year-old victim, was consistent, straightforward, and corroborated by medical findings. The Court emphasized that testimonies of young victims are credible, especially when they are consistent and supported by medical evidence.
   • The trial court’s assessment of witness credibility is accorded great respect, as it had the opportunity to observe the witnesses firsthand.

3. Defense’s Weakness:

   • Appellant Lopez’s defense relied solely on denial and an accusation against BBB’s 6-year-old brother. The Court ruled that affirmative testimony from credible witnesses prevails over bare denials.

4. Penalty and Damages:

   • Although the death penalty was initially imposed, it was reduced to reclusion perpetua under RA 9346. However, appellant is ineligible for parole.
   • The Court upheld the award of civil indemnity (P75,000.00) and increased moral damages to P75,000.00, consistent with jurisprudence on qualified rape. Exemplary damages were reduced to P30,000.00.