Facts:

The case involves the appeal of Jayson Tuazon y Olia (the appellant) who was found guilty of the crime of rape by the Regional Trial Court (RTC) of Pasig City, Branch 163. The Court of Appeals (CA) affirmed the RTC's decision with modification. The appellant was sentenced to suffer the penalty of Reclusion Perpetua and ordered to pay the victim, referred to as AAA, various amounts as civil indemnity, moral, exemplary, and nominal damages.

On March 3, 2001, around 3:30 in the morning, AAA was sleeping in her room when she was awakened by the appellant kissing her on her cheeks and lips. The appellant, who was her mother's common-law husband, proceeded to touch her breast and bite her nipples and breasts. He then poked a fan-knife at her and threatened her not to tell anyone. The appellant instructed AAA to go downstairs and cook porridge, which she was supposed to sell later. While she was cooking, the appellant guarded her and continued to touch her breasts and private parts. He also poked the fan-knife at her neck. After she finished cooking, the appellant told her to sit on her bed and continued to touch her. He then removed her shorts and panty, licked her body, and had sexual intercourse with her. AAA felt his penis coming in and out of her vagina. The appellant wiped her private part with his handkerchief and ordered her to dress up and take a bath. AAA did not obey him and instead brought out her merchandise while crying. When AAA's mother and sister returned home, AAA told them what the appellant had done to her. They immediately went to the police station to report the incident and had it recorded on the police blotter. AAA also underwent a medical examination.

The appellant was charged with rape and pleaded not guilty. The RTC found him guilty beyond reasonable doubt and sentenced him to Reclusion Perpetua. The CA affirmed the RTC's decision with modification on the award of damages.

Issue:

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Ruling:

The court ruled that the appellant's contentions were untenable. In rape cases, the credibility of the victim's testimony is of primordial consideration. The trial court found AAA's testimony to be candid, natural, forthright, and unwavering. The court accorded great weight and respect to the trial court's conclusions on the credibility of witnesses, unless there are facts or circumstances of weight and value that were overlooked or misappreciated. In this case, no such facts or circumstances exist.

The court found AAA's testimony to be consistent with the findings of the physician who examined her. The medical examination showed signs of physical trauma on AAA's genitalia, which corroborated her testimony of sexual abuse. The court also rejected the appellant's defense of consensual sex, as he failed to provide convincing evidence to support his claim. The court emphasized that no woman would cry rape, subject herself to humiliation and public trial, and risk her reputation if her claim were not true.

The court also found that the force and intimidation element of rape were present in this case. The appellant threatened AA...(Unlock)

Ratio:

The Court held that the credibility of the victim's testimony is crucial in rape cases. In this case, the trial court found AAA's testimony to be candid, natural, forthright, and unwavering. The court accorded great weight and respect to the trial court's conclusions on the credibility of witnesses, unless there are facts or circumstances of weight and value that wer...continue reading