G.R. No. 222497 - People vs. Rupal

Accused-appellant Pedro Rupal was charged with rape under Article 266-A of the Revised Penal Code, as amended by R.A. No. 8353.
The criminal case (Crim. Case No. 06-1748) alleged that on or about December 15, 2005, in a barangay of Bohol, Rupal forcibly committed rape on AAA, a 13-year-old minor.
The charging document described that the crime was committed through the use of force, threat, and intimidation, in violation of provisions on rape and other related statutes.

AAA, while at school preparing for a Christmas party, was approached at a waiting shed by the accused-appellant.
Rupal initially explained that AAA was to change a 100-peso bill for a 50-peso fare, but later returned to retrieve the remaining amount.
At approximately 1:00 p.m. on December 15, 2005, when AAA handed him the P50.00, Rupal:

Pulled the handle of her bag, causing it to detach.
Dragged her toward a nearby coconut plantation where he pushed her to the ground.
Removed her underwear and raised her skirt.
Mounted and inserted his erect penis into her vagina, performing a push-and-pull movement.
Kissing her lips and touching her breasts during the assault.

After the assault, Rupal threatened AAA by warning her not to inform her mother (BBB), threatening to kill her and her siblings.
A further incident on January 2, 2006, is noted where Rupal chased AAA as she was alighting from a jeep, and bystanders later alerted CCC, leading to further disclosure.

AAA provided a detailed and chronological account of the rape, narrating the events and specifics, including the physical abuse.
AAA’s mother, BBB, and the medical examiner, Dr. Analita N. Auza, testified:

BBB corroborated aspects of AAA’s narrative and later obtained AAA’s medical examination.
Dr. Auza conducted a perineal examination which revealed:

Healed lacerated wounds at specific clock positions (2, 7, and 11 o’clock) of the vaginal opening.
Evidence of vaginal penetration, as her hymen was not intact.

The doctor opined that the lacerations were compatible with forcible entry by a male genitalia.

Rupal, who is also the husband of DDD (sister of BBB), claimed innocence.
His version stated that on December 15, 2005, until 3:00 p.m., he was engaged in household chores and gardening with his children.
He contended that after fetching water at around 4:00 p.m., he stayed home until bedtime.
The accused did not execute any counter-affidavit when arrested in 2006.

The Regional Trial Court (RTC) found AAA’s testimony to be straightforward, believable, and credible, particularly given her age and vulnerability.
The RTC noted that the testimony was supported by physical evidence (medical findings) despite minor inconsistencies.
The RTC convicted Rupal of rape and sentenced him to reclusion perpetua, along with an order to pay civil indemnity to AAA of P50,000.00.

Rupal appealed on grounds disputing the credibility of AAA’s testimony and the sufficiency of evidence.
The CA affirmed the RTC’s findings, giving full weight to AAA’s credible and consistent testimony.
The CA modified the award of damages, ordering Rupal to pay:

The CA dismissed the appeal, sustaining the conviction on the basis that all elements of rape had been proven beyond reasonable doubt.

Whether the trial court erred in placing significant weight on the testimony of AAA despite alleged inconsistencies, particularly regarding the number of times the rape was committed.
Whether the minor’s testimony, given her age and vulnerability, should be corroborated or given lesser credence due to conflicting accounts (e.g., the differing numbers of alleged rapes as testified by AAA and BBB).

Whether the prosecution successfully established all the elements of rape, namely, that Rupal had carnal knowledge of AAA by means of force, threat, or intimidation.
Whether the defense’s arguments of alibi and denial were proven or sufficiently rebutted by the positive, corroborated evidence presented by the prosecution.

Whether the accused’s defense of being engaged in household chores and fetching water sufficiently exonerated him from being present at the scene.
Whether the absence of counter-testimonies to support the alibi weakened the accused’s case beyond mere denial.