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PEOPLE v. REGGIE BRIONES Y DURAN

FACTS:

Reggie Briones y Duran was charged with the crime of rape and violation of R.A. No. 7610. The prosecution presented testimonial and documentary evidence to establish that Briones forcefully had carnal knowledge with the victim, FFF, who was a 12-year-old child at the time. FFF tried to resist and pleaded for him to stop, but Briones threatened her and her family. The sexual abuse happened multiple times and FFF kept it a secret until her parents discovered her ordeal. Briones denied the accusation and claimed that he and FFF were in a consensual romantic relationship. The RTC found Briones guilty of rape and sentenced him to reclusion perpetua. The CA affirmed the decision with modifications to the damages awarded. Briones appealed to the Supreme Court, but the Court found no reason to reverse the lower court's decision, thereby affirming Briones' conviction.

ISSUES:

  1. Whether or not the elements of the crime of rape were duly proven in this case.

  2. Whether the testimony of FFF should be given full faith and credence.

RULING:

  1. Yes, the elements of the crime of rape were duly proven. The trial court's evaluation and conclusion on the credibility of witnesses in rape cases are generally accorded great weight and respect. In this case, the trial court's findings were upheld by the appellate court. The victim's testimony that she tried to push the accused away and pleaded for him to stop was considered credible. The defense of the accused that the sexual encounter was with the consent of the victim, based on their alleged love affair, was rejected. The court held that being sweethearts does not establish consent to the sexual act. The accused failed to provide compelling evidence to support his "sweetheart defense." It was also noted that the victim was only twelve years old at the time of the rape, and it is not necessary that the force and intimidation employed be so great or irresistible. The force or intimidation need only be sufficient to consummate the accused's purpose or impel the victim to submit. The court also rejected the argument that the victim and her family were motivated by scandal and shame, as it would be more scandalous for the victim to undergo the process of putting the accused, a family friend, behind bars. The victim's testimony was found to be credible and the accused was found guilty beyond reasonable doubt.

  2. Yes, the testimony of FFF should be given full faith and credence. Briones is found guilty beyond reasonable doubt of the crime charged.

PRINCIPLES:

  • The elements of rape under Article 266-A of the Revised Penal Code (RPC) include force, threat, or intimidation.

  • Rape can still be prosecuted and penalized under the RPC even if the elements of both violations of Section 5(b) of R.A. No. 7610 and Article 266-A, paragraph 1(a) of the RPC are alleged and proven.

  • Inconsistencies in the trial court's decision may be of little significance if the prosecution was able to establish the accused's guilt beyond reasonable doubt through competent evidence.

  • The trial court's evaluation and conclusion on the credibility of witnesses in rape cases are generally accorded great weight and respect, and at times even finality. Trial judges are in the best position to assess whether a witness is telling the truth or lying.

  • The "sweetheart" defense in rape cases must be proven by compelling evidence, showing that the accused and the victim were lovers and that the victim consented to the sexual relations. Love is not a license for lust.

  • Force or intimidation, as an element of rape, need not be irresistible. It may be just enough to bring about the desired result. What is necessary is that the force or intimidation be sufficient to consummate the purpose that the accused had in mind or is of such a degree as to impel the defenseless victim to submit.

  • The testimony of a young and immature victim in a rape case is given considerable reception by the trial courts, considering the victim's vulnerability and the shame and embarrassment she experiences throughout the court trial. A victim would not willingly subject herself to the rigors, humiliation, and stigma of a rape trial if not motivated by a genuine desire to put the culprit behind bars.

  • The testimony of a witness is entitled to full faith and credence, especially when it is clear, straightforward, and consistent with human nature and the normal course of things.

  • When the trial court's findings of fact have been affirmed by the appellate court, the same are binding and conclusive on the Supreme Court, absent any showing of arbitrariness or oversight of facts or circumstances of material significance.