Case Digest: PEOPLE OF THE PHILIPPINES v. EFREN G. DE TAZA 410 SCRA 518

PEOPLE OF THE PHILIPPINES v. EFREN G. DE TAZA 410 SCRA 518 

Medical findings of injuries in the victim’s genitalia are not essential in rape cases. Efren De Taza, an officer of the Philippine Airforce (PAF), was charged with four (4) counts of rape commited against his minor stepdaughter. The medical examination of the victim proved inconclusive regarding the said rape. Upon hearing of the case, the witness testified regarding the alleged rape committed against her. The Regional Trial Court of Cavite found De Taza guilty of four (4) cunts of rape and the penalty of death was imposed. Hence, the automatic review of the Court.

ISSUE:

Whether or not the Court of Appeals erred in finding De Taza guilty of rape

HELD:

In his Brief, De Taza draws attention to matters testified on by AAA which to him create doubts on the credibility of her testimony. He particularly cites her account of the May 15, 1993 incident (subject of the first information) that De Taza was able to insert his penis into her vagina which is belied by the medico-legal report conducted on her following such incident indicating that there was no evident sign of extra-genital injuries and that her hymen was still intact. It is well settled that for a conviction of rape, medical findings of injuries in the victim‘s genitalia are not essential. The above-quoted findings of Dr. Bernales on his examination of AAA on May 17, 1993, two days after the May 5, 1993 incident – subject of the first information, merely rule out complete penetration.