FACTS:
Accused-appellant Michael Quinto was charged with the rape of minor complainant, AAA. The prosecution presented evidence that accused-appellant brought AAA to another house where he undressed her and had sexual intercourse with her against her will. AAA reported the incident to her aunt, who informed AAA's mother. AAA underwent a medical examination and was found to have injuries consistent with rape, and a psychological examination revealed that she had mild mental retardation. Accused-appellant denied the charge and claimed he and AAA were in a consensual relationship. Despite the defense's arguments, the trial court convicted accused-appellant of rape.
The Regional Trial Court found the prosecution's evidence, particularly AAA's testimony, credible and reliable, while it found accused-appellant's defense of denial and alibi to be incredulous. The court rejected the sweetheart defense presented by accused-appellant, stating that it did not outweigh AAA's positive identification and straightforward testimony.
The Court of Appeals affirmed accused-appellant's conviction, stating that AAA's testimony was believable and sufficient to establish the incident of rape. The appellate court also rejected accused-appellant's sweetheart theory and alibi defense.
Accused-appellant then filed a Notice of Appeal, arguing that it was highly impossible for him to have committed the rape within public view and in broad daylight. He questioned why AAA did not seek help when they were in a house with other people. He insisted on the appreciation of his sweetheart defense, claiming it was supported by credible witnesses. The prosecution countered that accused-appellant's guilt was proven beyond reasonable doubt through AAA's clear, categorical, and straightforward testimony, with no motive other than seeking justice.
ISSUES:
-
Can a person be accused and convicted of both rape under Article 266-A paragraph 1(a) of the Revised Penal Code (RPC) and sexual abuse under Section 5(b) of Republic Act No. 7610?
-
Should a felony, particularly rape, be complexed with an offense penalized by a special law, such as Republic Act No. 7610?
-
Whether the testimonies of child victims are given full weight and credit.
-
Whether the testimonial evidence of a single witness can suffice for conviction.
-
Whether the defense of alibi is valid when it was physically possible for the accused to be at the scene of the crime.
-
Whether the "sweetheart" defense is tenable in rape cases.
-
Whether the court below erred in finding accused-appellant guilty beyond reasonable doubt of rape committed through force and intimidation.
-
Whether the "sweetheart" theory interposed by accused-appellant should have been given substantial corroboration.
RULING:
-
If the victim is 12 years or older, the offender cannot be accused of both rape under Article 266-A paragraph 1(a) of the RPC and sexual abuse under Section 5(b) of R.A. No. 7610 because it may violate the right of the accused against double jeopardy.
-
A felony, in particular rape, cannot be complexed with an offense penalized by a special law, such as R.A. No. 7610.
-
Yes, the testimonies of child victims are given full weight and credit. The court recognizes that when a woman or a girl says that she has been raped, she says in effect all that is necessary to show that rape was indeed committed. The Court also takes into consideration the findings of a medical expert, who stated that the victim suffered from mild mental retardation and had the mental capacity of a child. It is highly improbable that the victim concocted the story.
-
Yes, the testimonial evidence of a single witness can suffice for conviction. The prosecution is not required to present a definite number of witnesses. The weight of the witness's testimony is more important than the number of witnesses. In this case, the victim's testimony, as the sole eyewitness, should not diminish her credibility.
-
No, the defense of alibi is not valid when the accused could have been physically present at the scene of the crime. The accused-appellant was within the immediate vicinity of the crime scene, and it was not physically impossible for him to be there at the time of the crime. Therefore, his defense of alibi fails.
-
The "sweetheart" defense is not tenable in rape cases. The claim must be substantiated by evidence such as notes, gifts, pictures, or other mementos that indicate the existence of a romantic relationship. In this case, there was insufficient evidence to prove the existence of a romantic relationship between the accused-appellant and the victim.
-
The court below did not err in finding accused-appellant guilty beyond reasonable doubt of rape committed through force and intimidation.
-
The "sweetheart" theory interposed by accused-appellant was correctly rejected for lack of substantial corroboration.
PRINCIPLES:
-
A more recent law prevails over an earlier law in case of irreconcilable conflict between the two.
-
The trial court's assessment of the credibility of witnesses deserves great weight, especially when it is not tainted with arbitrariness or oversight of some fact or circumstance of weight and influence.
-
Testimonies of child victims are given full weight and credit.
-
The weight of a witness's testimony is more important than the number of witnesses.
-
The defense of alibi must prove that it was physically impossible for the accused to be at the scene of the crime.
-
The "sweetheart" defense must be substantiated by evidence of a romantic relationship. Love is not a license for lust.
-
Rape committed through force and intimidation is punishable by reclusion perpetua under Article 266-B of the Revised Penal Code.
-
When rape is committed with the use of a deadly weapon, the penalty shall be reclusion perpetua to death.
-
The proper penalty to be imposed for rape committed with a deadly weapon is "reclusion perpetua without eligibility of parole."