People of the Philippines vs. Restituto C. Valenzuela

G.R. No. 182057, February 6, 2009; per Brion, J.

Facts

Sometime in 1994 while the victim’s mother was not at home in Brgy. Concepcion, Aroroy, Masbate, and the victim was the only child left at their house since her younger brothers were then playing somewhere, the accused who was his father ordered her to get inside the bedroom, undressed his own daughter, sucked her breast, kept on kissing her whole body. Then her father inserted his finger in her vagina and inserted his penis into the vagina of AAA who felt the pain then the accused began the push and pull or pumping on top of his daughter. The accused repeatedly raped her from 1994 to 1998, the last incident being in January 1998. She gave birth on October 20, 1998, and pointed to the appellant as the father of the child.

Issue

Whether or not evidence presented by the prosecution is sufficient to prove his guilt beyond reasonable doubt

Ruling

The Supreme Court ruled that the evidence presented by the prosecution is sufficient to prove respondent’s guilt beyond reasonable doubt. Rape is defined and penalized under Article 335 of the Revised Penal Code, as amended. Paragraph 3 thereof is termed statutory rape which is carnal knowledge of a woman below twelve (12) years old. Thus, force, intimidation, and physical evidence of injury are immaterial; the only subject of inquiry is the age of the woman and whether carnal knowledge took place. The law presumes that the victim does not and cannot have a will of her own on account of her tender years; the child’s consent is immaterial because of her presumed incapacity to discern evil from good. However, the accused may be convicted solely on the testimony of the victim, provided the testimony is credible, natural, convincing, and consistent with human nature and the normal course of things.

In this instant case, not only did AAA identify his father as her rapist, but she also recounted the rape in detail, particularly how the sexual intercourse took place. The court found no indication that AAA’s testimony is in a suspicious light. Her account of her harrowing experience was candid and straightforward. She remained resolute and unswerving even on cross-examination. To our mind, her testimony deserves full faith and credit.