G.R. No. L-58847 - People vs. Barranco

Appellant Oscar Santos y Encinas was charged in 16 separate informations: one count of rape (in relation to RA 7610) and 15 counts of acts of lasciviousness (violation of Article 336 of the Revised Penal Code in relation to Section 5 of RA 7610).
The offenses involved sexual abuse against AAA, the appellant’s seven- to eight-year-old goddaughter.

The allegation stated that in or about June 1997 in Orion, Bataan, the appellant, through the use of force and intimidation and motivated by lust, had carnal knowledge with AAA—his seven-year-old goddaughter.
It was charged that the act was committed against the will of the minor, to her damage and prejudice.

The indictment comprised 15 counts alleging that on various dates from July 1997 to September 1998, the appellant repeatedly kissed AAA’s neck and lips and licked her sex organ.
On two specific occasions (in July and August 1997), he was also accused of forcibly inserting his penis into her mouth.
The offenses were charged under Article 336 of the RPC in relation to Section 5 of RA 7610.

AAA testified that in June 1997, while playing alone, the appellant grabbed her and silenced her by covering her mouth.
He then took her to his house where he conducted a series of sexual acts including removing her panties, licking her vagina, and poking his penis into her vagina while she experienced pain and resistance.
It was further testified that, on a monthly basis from July 1997 to September 1998, the appellant would bring her to his house and repeat acts of kissing, licking, and on two occasions, inserting his penis into her mouth.
AAA expressed that she did not report the incidents initially out of fear.

AAA’s mother recounted that a relative had informed her in September 1999 about similar molestation allegations involving another minor, prompting her to question AAA who then disclosed the events.
Medical evidence from the Bataan General Hospital was introduced, though the Medico-Legal Certificate stated that AAA’s hymen was intact with a wider opening.

The appellant, the sole defense witness, denied the alleged sexual abuse.
He claimed that he was a fisherman largely at sea during the period in question and that the only exception was taking a day off on Good Friday.
The defense presented alibi evidence; however, no corroborative testimony was offered to support this claim.

The trial court found the appellant guilty beyond reasonable doubt of rape in Criminal Case No. 7587 and of 15 counts of acts of lasciviousness in the separate criminal cases.
The sentencing included reclusion perpetua for rape and a range of penalties for the acts of lasciviousness, along with orders for payment of civil indemnity, moral damages, and exemplary damages in specified amounts.

The Court of Appeals affirmed the trial court’s ruling with modifications.
Modifications included adjustments to the amounts of damages and civil indemnity for both the rape count and the 15 counts of acts of lasciviousness, as well as the imposition of a different range of sentences for the latter based on the applicable penalty ranges under RA 7610.
The appellate court found that the positive and detailed testimony of AAA outweighed the appellant’s denial and uncorroborated alibi.

Whether the testimony of AAA, being consistent and detailed, was adequate to establish the guilt of the appellant beyond reasonable doubt.
Whether any evidence was provided to show that AAA had any ill motive to fabricate her testimony.

The effectiveness and credibility of the appellant’s denial as an explanation for the crimes.
Whether the uncorroborated alibi and self-serving negative evidence provided by the appellant could overcome the positive and consistent testimony of the victim.

The legal classification of the incident in relation to rape versus acts of lasciviousness, especially considering the two incidents where the appellant allegedly inserted his penis into the victim’s mouth.
The impact of RA 8353 (the Anti-Rape Law of 1997) on the classification, given that the incidents occurred before its effectivity.

Whether the imposed penalties and the awarded damages are consistent with the requirements of the Revised Penal Code, RA 7610, and prevailing jurisprudence.
Whether the modifications by the Court of Appeals, particularly on the damages and the range of imprisonment for acts of lasciviousness, were properly supported by law.