G.R. No. 222219 - Geraldo vs. The Bill Sender Corp.

The case involves the People of the Philippines as appellee against Manuel "Awil" Pojo, the appellant.
The criminal charge is statutory rape, with the prosecution alleging that the appellant committed the offense against a minor identified as "AAA."

An Information was filed on March 16, 2004, charging the appellant with statutory rape.
The incident is alleged to have occurred on October 20, 2003, around three o’clock in the afternoon at a location in Camarines Sur, Philippines.
According to the charge, the appellant, by means of force and intimidation, had carnal knowledge of "AAA," a girl ten years old at that time.
Key elements of the incident:

"AAA" was sent by her mother to deliver food to the appellant, who was reportedly working at a camote plantation.
The appellant allegedly ordered "AAA" to lie on the ground and removed his undergarments before committing the act.
The penetration was described as incomplete, with the appellant’s penis merely touching her private parts; however, "AAA" experienced pain in her private organ.
Shortly after the incident, the appellant ordered "AAA" to go home.

"AAA" testified that the appellant was the common-law husband of her mother, a fact later corroborated by additional evidence during trial.
"AAA" promptly reported the incident to her sibling and mother, which then led to a police report and a subsequent medical examination.
The credibility of "AAA" was emphasized by her detailed recollection despite her young age, being 10 at the time of the incident and 12 when testifying in court.

The appellant admitted the relationship with "AAA’s" mother but denied the commission of statutory rape.
The defense contended that:

The appellant was in Batangas on October 20, 2003, working in a sugarcane plantation for his cousin, Mariano Ate.
"AAA’s" motive in filing the charge was to force him into marriage with her mother.

The defense failed to present independent evidence or witnesses to substantiate the alibi or to corroborate the appellant’s whereabouts.

The RTC found the appellant guilty beyond reasonable doubt of statutory rape, relying primarily on the positive and credible testimony of "AAA."
The court observed that even though complete penetration did not occur, the testimony and physical evidence (whitish substance observed by "AAA") supported the commission of the crime.
The RTC sentenced the appellant to reclusion perpetua and ordered him to pay P50,000 as civil indemnity and another P50,000 as moral damages to "AAA."

The CA affirmed the RTC’s decision in toto.
It upheld the credibility of "AAA’s" testimony, finding the appellant’s alibi to be unsubstantiated and self-serving.
The CA dismissed the defense’s claim regarding the motive of "AAA" filing the complaint.

The Supreme Court (SC) reviewed the case and found no merit in the appellant's appeal.
It affirmed that the delay in filing "AAA’s" affidavit (27 days after the alleged incident) did not detract from her credibility or the strength of the evidence.
The SC reiterated that a mere denial or uncorroborated alibi cannot overcome a positive and credible identification by the victim.
In addition to affirming the imprisonment penalty, the SC modified the damages awarded by ordering exemplary damages of P30,000 to "AAA" on top of the previously awarded civil indemnity and moral damages.

Whether the evidence, particularly the testimony of "AAA," was sufficient to prove the appellant’s commission of statutory rape beyond reasonable doubt.
Whether the nature of the penetration (incomplete but causing pain) meets the elements of the crime under statutory rape provisions.

Whether "AAA’s" testimony, given her age and the 27-day delay in affixing her affidavit, was persuasive and credible.
The impact of the delay on the assessment of witness reliability and the overall evidentiary value of her testimony.

Whether the appellant’s claim of being in Batangas during the incident was supported by clear and convincing evidence.
Whether the motive alleged by the defense—that "AAA" filed the charge to force the appellant to marry her mother—was plausible given her age and circumstances.

Whether the damage awards, including civil indemnity, moral damages, and exemplary damages, were in accordance with existing jurisprudence and the evidentiary record.
Whether the establishment of the qualifying circumstance (being the common-law husband of the victim’s mother), although not included in the Information, warranted the order for exemplary damages.