People of the Philippines vs. Antonio Venturina
G.R. No. 183097 ; 12 September 2012
PONENTE: Del Castillo
SUBJECT: Rape, Credibility of Child Witness
FACTS:
Version of the Prosecution:
The victim, AAA, is the daughter of the accused. On 24 April 2002 at around 8:00 PM, Accused came home drunk and was having difficulty to breath and he was crying. At that time, AAA was with her brothers who were already sleeping. AAA massaged the accused’s chest until he stopped crying. Unexpectedly, accused then embraced and kiss her on the cheeks. He started removing his clothes and the clothes of the victim who attempted to resist. He then got on top of her and had carnal knowledge with the victim. When the brother of AAA woke up, he dragged the victim outside the house and to an area near their chicken pen and continued to have carnal knowledge with the victim. At daybreak, accused stopped ravishing AAA and threatened her not to tell anybody. Accused then left to see his wife, the mother of AAA, to ask for money to pay the electric bills. After the accused had left, AAA went to report the incident to her sister who reported the same to the police. AAA then executed a Sinumpaang Salaysay (Sworn Statement).
Version of the Defense:
On 24 April 2002, Accused tilled the land beside the hut where he and his family was staying from 7:00 AM – 5:00 PM. He then went home to take his snack but AAA was not home, who left without asking permission. When AAA arrived home, accused forbade her to mingle with her friends, who are allegedly drug users, and AAA was grounded for a week. Later, accused passed out due to his chest pains and only regained consciousness at 4:00 AM the following day. He then went to his wife to ask for money then he returned home. He did not find AAA at home but she later arrived with the police who arrested her.
ISSUE:
Whether or not the allegations of the accused is credible to cast a reasonable doubt which would warrant his acquittal.
HELD:
No, in the appreciation of the evidence for the prosecution and the defense, the settled rule is that the assessment of the credibility of witnesses is left largely to the trial court. And in almost all rape cases, the credibility of the victim’s testimony is crucial in view of the intrinsic nature of the crime where only the participants therein can testify to its occurrence. Once found credible, the victim’s lone testimony is sufficient to sustain a conviction. Absent therefore any substantial reason to justify the reversal of the assessments and conclusions of the trial court especially if such findings have been affirmed by the appellate court, the evaluation of the credibility of witnesses is well-nigh conclusive to this Court. Testimonies of child victims of rape are given full weight and credit, for youth and immaturity are badges of truth. AAA’s testimony is corroborated by the finding of the Doctor who examined her thus the Supreme Court held that when the testimony of a rape victim is consistent with the medical findings, sufficient basis exists to warrant a conclusion that the essential requisite of carnal knowledge has thereby been established.
In addition, the Supreme Court did not find credence in the allegation of the Accused that the lacks of any form of injury or fresh hymenal lacerations negate the commission of rape. Settled is the doctrine that absence of external signs or physical injuries does not negate the commission of rape. Physical injuries or hymenal lacerations are not essential elements of rape.
The accused was convicted for two (2) counts of rape and was sentenced to Reclusion Perpetua, not death, pursuant to REPUBLIC ACT NO. 9346 – An Act Prohibiting the Imposition of Death Penalty in the Philippines
