Case Digest: PEOPLE OF THE PHILIPPINES v. CRISPIN PAYOPAY 417 SCRA 463 (2003)

PEOPLE OF THE PHILIPPINES v. CRISPIN PAYOPAY 417 SCRA 463 (2003)

“Sexual abuse” cannot be equated with rape, absent any showing, nay claim, that the accused’s organ entered or penetrated the victim’s pudendum. Crispin Payopay was charged before the Regional Trial Court with the crime of rape committed against AAA. During the trial, AAA stated that she was ―sexually abused‖ by Crispin. The lower court found Payopay guilty of the crime charged.

ISSUE:

Whether or not the testimony of AAA is sufficient to convict Crispin Payopay

HELD:

 
An accused may be convicted [of rape] on the basis of the lone, uncorroborated testimony of the rape victim, provided that her testimony is clear, positive, convincing and otherwise consistent with human nature. However, AAA‘s testimony does not pass the test of credibility. In fact, even gratuitously crediting the victim‘s account that appellant ―abused‖ her, the Court does not appreciate the commission of rape. Thus, she claimed that she was ―abused‖ or ―sexually abused‖ as her counsel suggested. ―Sexual abuse‖ cannot, however, be equated with rape, absent any showing, nay claim, that AAA‘s organ entered or penetrated the victim‘s pudendum.

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