Case Summary (G.R. No. 131516)
Trial Court Proceedings
At the Quezon City RTC, AAA, her mother, the medico-legal officer, and a police officer testified for the prosecution. The defense presented only the accused, who denied the acts and suggested malice by AAA’s mother. The court admitted respondent’s out-of-court admission to AAA’s parents and took note of his silence at trial regarding that admission.
Medical Findings
Dr. Ma. Cristina Preyra examined AAA on November 21, 1995. She found congested and abraded labia minora, an intact hymen, and no external signs of recent trauma. She opined that the abrasions could have been caused by friction with an erect penis and discounted other causes.
Defense’s Account
Respondent claimed he merely bought medicine for AAA’s urinary difficulty and that Gloria Buenafe harbored personal animus against him. He denied any sexual contact with AAA and suggested the complaint was maliciously fabricated.
Trial Court Judgment
The RTC convicted respondent of rape and imposed the death penalty, plus P 40,000 civil indemnity. The conviction rested on AAA’s credible testimony, respondent’s admission to her parents, and the medical report.
Issues on Appeal
Respondent argued that:
- His out-of-court admission was coerced and inadmissible.
- His silence at trial should not be treated as an implied admission.
- The evidence failed to prove guilt beyond reasonable doubt.
- The death penalty was excessive.
Admission of Guilt and Admissibility
The Supreme Court held that even if respondent’s admission to AAA’s parents were disregarded, the remaining evidence—AAA’s testimony and the medical report—sufficed to prove rape beyond reasonable doubt. His silence at trial did not alter the outcome.
Credibility of the Victim’s Testimony
AAA’s detailed, spontaneous, and consistent narrative was found credible. Despite her tender age, she demonstrated intelligence, awareness of right and wrong, and provided vivid descriptions of the assault, which she repeated under cross-examination.
Medical Corroboration of Penetration
Dr. Preyra’s findings of labial abrasions directly beneath the labia majora corroborated AAA’s account of penile penetration. These injuries could not reasonably be self-inflicted nor caused by innocuous activities such as bicycle riding.
Age as Element and Qualifying Circumstance
Statutory rape under Article 335 requires carnal knowledge of a woman under 12. The victim and her mother testified that AAA was three years old. No birth or bap
...continue readingCase Syllabus (G.R. No. 131516)
Facts of the Case
- Victim “AAA” was a three-and-a-half-year-old child living in Quezon City with her parents and accused-appellant Ronnie Rullepa y Guinto, the family’s houseboy.
- On or about November 17, 1995, Rullepa allegedly removed AAA’s panty, kissed her lips and vagina, then rubbed and inserted his penis into her vagina, anus, and mouth by force and intimidation.
- Three days later (November 20), AAA spontaneously told her mother, Gloria Buenafe, “Kuya Ronnie placed his titi and stabbed it in my puwit and in my mouth.” She pointed to Rullepa’s pillow as the scene of the repeated abuse.
- Gloria and her husband confronted Rullepa that night; he admitted the act once at “4:00 p.m. of November 17, 1995.” He was detained after giving a sworn statement.
- At trial AAA provided graphic, consistent accounts of two separate episodes in Rullepa’s bedroom, describing pain, crying, and the nature of the assault.
Procedural History
- January 15, 1996: Accused arraigned in RTC Quezon City (Branch 96), pleaded not guilty to rape.
- Prosecution witnesses: AAA, her mother Gloria Buenafe, Dr. Ma. Cristina V. Preyra (Medico-Legal Officer), and SPO4 Catherine Borda.
- Defense witness: Accused-appellant Ronnie Rullepa, who denied wrongdoing and alleged malicious prosecution by AAA’s mother.
- The RTC convicted Rullepa of rape, sentenced him to death, and ordered P 40,000 civil indemnity.
- Automatic review by the Supreme Court; accused assigned errors on admissibility of his admission, implied guilt by silence, sufficiency of proof, and imposition of death penalty.
Issues Presented
- Whether the trial court erred in admitting Rullepa’s confession to the victim’s parents.
- Whether the court properly t