G.R. No. 113057-58 - People vs. Remoto y Fajela

Two separate criminal complaints were filed on January 10, 1992, at the RTC of Bataan, charging appellant Juan “Johnny” Fajela Remoto with rape in two distinct cases.
The offenses involved the sexual abuse of two minor complainants, Leslie Marris Santos and Carabella J. Viray, both six years old at the time of their respective assaults.

Occurred in December 1989 in Mariveles, Bataan.
Appellant, entrusted with taking Leslie to school and back via his tricycle (a job for which he was known and trusted in the community), deviated from his usual route.
Brought her to a spot near the Mormon Church under the guise of a game involving scattered coins, during which he ordered her to bend over.
In a moment of premeditated abuse, he stealthily approached, lifted her skirt, and inserted his penis into her vagina, causing significant physical pain.
The child was intimidated into silence with threats regarding her return home.

Occurred in April 1991 in Mariveles, Bataan, shortly after Carabella graduated from Kindergarten.
During a brown-out, the appellant lured Carabella with a promise of buying a lollipop.
Instead of taking her to a candy store, he brought her to the neighboring Maglalang residence where he was known to frequent.
In an unguarded room (Allan Maglalang’s room, which was unlocked), he removed her short pants, made her lie down on a bed, and proceeded to forcibly insert his penis into her, causing pain and distress.
The abuse was witnessed indirectly when Carabella’s older sister, Brendalyn Viray, encountered the scene, leading to further complications.

The complainants provided detailed and graphic testimonies of the rapes, recounting the events in a clear and spontaneous manner, despite their youth.
Medico-legal examinations supported the testimonies with findings such as a healed laceration on Leslie’s hymen and an enlarged hymenal opening in Carabella.
Additional minor witness Brendalyn Viray corroborated parts of the incidents, despite minor inconsistencies that were deemed immaterial.
Defense witnesses attempted to establish an alibi, including one who claimed that appellant was absent from the scene, yet their statements were contrary to other available evidence and the physical proximity of the events.
The defense also argued that the testimonies of the minor complainants could have been influenced by external factors or were inconsistent; however, the court found these arguments unconvincing given the nature of the evidence.

The trial court, after evaluating the credible evidence and eyewitness testimonies, found the appellant guilty beyond reasonable doubt for two counts of rape.
The court emphasized the reliability of the minor witnesses’ accounts despite their tender age, noting the inherent credibility in the spontaneous and candid manner in which the children narrated the events.
The conviction was upheld with the appellant being sentenced to reclusion perpetua for each count, along with the imposition of indemnification payments and additional accessory penalties.

The appellant advanced defenses based on denial and alibi, contending that the trial court erred in accepting the testimonies due to supposed infirmities in the witnesses’ recollections.
He argued that inconsistencies in the details, such as the timing and location nuances, or the behavior of the victims following the incidents, should preclude conviction.
The appellate court, however, noted that inconsistencies were minor and did not detract from the overall credibility and consistency of the victims’ testimonies.

Whether the trial court erred in finding the accused guilty beyond reasonable doubt on the basis of the testimonies of the minor complainants and other supporting evidence.
Whether inconsistencies in the testimonies of the witnesses, due to the victims’ tender age and the conditions involved (such as a brown-out), undermine the probative value of their accounts.
Whether the defense’s arguments on denial and alibi, including the challenge on the reliability of child witnesses, were sufficient to overturn or doubt the trial court’s conviction of statutory rape.