People of the Philippines vs. Morante
G.R. No. 187732, November 28, 2012
Ponente: Leonardo – De Castro, J.:
Facts:
Version of the prosecution: Morante was found guilty beyond reasonable doubt of the crimes of violation of section 5(b) of R.A. No. 7610 and 6 counts of rape as defined in Art.266-A of the RPC. It was alleged that Morante taking advantage of the minority of AAA who was 12 years old and of his moral ascendancy and influence over her as a common law husband mother unlawfully and feloniously, by means of force and intimidation with lewd designs fondle the breast of AAA, kiss her and took other unwarranted liberties of her body which degraded and demeaned her intrinsic worth and dignity as a human being. A separate charged of six counts of rape is likewise filed. The prosecution presented AAA as the witness, her birth certificate and medical certificate by Dr. Richard Viray. AAA testified that despite living with the family in close quarters, the accused repeatedly violated her all the while threatening to kill her if she made noise or reported the incident to anyone else. It was corroborated by the findings of Dr. Viray, stating that there are lacerations found on the examination.
Version of the Defense: Accused denied the charges against him. Stating that AAA, BBB, and CCC the aunt of AAA have harbored ill-feelings against him and disclaimed that he had no knowledge of any sexual abuse against AAA, because AAA infact worked as a helper in Bocaue, Bulacan and it was impossible for him to do anything against AAA. Aside from the fact that he treated AAA as his own daughter.
The trial court despite convicted him of the crime charged.
Issue:
Whether appellant’s guilt of the crime charged was not proven beyond reasonable doubt because of the alleged inconsistencies of AAA’s testimony.
Ruling:
No. The appeal must be dismissed for lack of merit. The SC reiterates the jurisprudential principle of affording great respect and even finality to the trial courts assessment of the credibility of witnesses. Besides, inconsistencies of the victim’s testimony do not impair her credibility, especially if the inconsistencies refer to trivial matters that do not alter the essential facts of the commission of the crime of rape. It is also notable that AAA was able to reconcile such inconsistency during the re-direct examination when she explained the same. A rape victim is not expected to make errorless recollection of the incident that is so humiliating and painful that she might in fact be trying to obliterate it from her memory. Thus a few inconsistent remarks in rape cases will not necessarily impair the testimonies of the offended party.
