G.R. No. 185389 - People vs. Resurreccion

On 20 June 2001, Benjie Resurreccion was charged before the Regional Trial Court (RTC) of Malaybalay, Bukidnon, Branch 8, for rape under Article 266-A of the Revised Penal Code, as amended by Republic Act No. 8353.
The RTC, in a decision dated 30 August 2005, found Resurreccion guilty of simple rape, sentencing him to reclusion perpetua and ordering him to pay damages to the victim.
Resurreccion appealed the RTC’s decision; the Court of Appeals, in its Decision dated 24 March 2008, affirmed the RTC’s conviction with modifications regarding the award of damages, awarding P50,000.00 as civil indemnity and another P50,000.00 as moral damages.

The alleged assault occurred on or about 5 December 2000 in the afternoon at the residence where Resurreccion was employed as a domestic helper.
Victim AAA, an 11-year-old girl, was descending from the second floor of her house when Resurreccion suddenly grabbed her arm.

Resurreccion covered the victim’s mouth with his left hand and forcibly dragged her into her room.
Once inside, he forcibly pinned her to the bed by holding her hands at her back.
He removed her short pants, panties, and T-shirt before proceeding with the sexual act, which involved inserting his penis into her vagina.
The victim experienced pain during the incident and was later intimidated with a warning not to disclose what had happened.

Fearing a recurrence of abuse due to the threat, AAA reported the incident the following day to her aunt, BBB, which then prompted her mother to take action and file a report with the police.
Medical examination was conducted two days later (on 7 December 2000) by Dr. Marlyn Valdez-Agbayani at the local Health Center, wherein it was noted that there were no lacerations on the external genitalia or hymen, and no spermatozoa were detected.

Testimonies of the victim (AAA) and her relative (BBB) detailed the chain of events, providing a vivid narrative of the abuse.
Medical testimony provided by Dr. Valdez-Agbayani explained that the absence of hymenal lacerations could be attributed to the elasticity and thinness of the victim’s hymen and that the two-day delay in the examination might explain the absence of spermatozoa.
Documentary evidence, including AAA’s Certificate of Live Birth, was presented to establish her age as 11 years old at the time of the incident.

Resurreccion presented a testimony of denial, contending that AAA and her family fabricated the charges due to personal animosity, alleging that disputes and suspicions of theft played a role in the false accusation.
The defense argued that the physical position maintained during the incident (with one hand covering the victim’s mouth and the other pinning her down) made it improbable for the rape to be consummated.
The absence of spermatozoa was also cited by the defense as evidence negating the possibility of rape.

Both courts found the victim’s testimony to be credible and consistent, noting that her account was detailed, candid, and not influenced by external motives.
The courts stressed that the inherent nature of rape cases requires careful scrutiny of the complainant’s credibility, especially given the typical isolation and secrecy surrounding such crimes.

The trial court determined that the testimony of the 11-year-old victim sufficiently established that she had been forced into a sexual act, despite the absence of physical corroborative evidence like spermatozoa or definitive hymenal lacerations.
In affirming Resurreccion’s conviction, the courts reaffirmed that the circumstantial and testimonial evidence was sufficient to prove simple rape beyond reasonable doubt.

Whether the cumulative evidence, particularly the victim’s testimony, was sufficient to prove beyond reasonable doubt that Resurreccion committed rape.
Whether the absence of corroborative physical findings (i.e., the lack of spermatozoa and hymenal lacerations) could undermine the established credibility of the victim’s account.

Whether the detailed and consistent narrative provided by the minor victim could be discredited by the defendant’s uncorroborated testimony of denial and allegations of familial animosity.
The extent to which the courts should rely on the intrinsic nature of rape cases, where the victim’s account often stands as the primary evidence.

Whether the facts established during trial correctly categorized the offense, considering the victim’s age and the nature of the act, as either statutory rape or simple rape under the prevailing legal framework.
Whether the doctrine that rape does not require physical evidence of force (such as spermatozoa) is applicable in this case.

Whether the penalty of reclusion perpetua imposed on Resurreccion was commensurate with the nature of the crime.
Whether the revised award of damages (civil indemnity and moral damages) by the Court of Appeals was justified based on the evidence presented.