**Facts:**
On April 16, 2002, 12-year-old AAA had an altercation with her father (CCC) and left home to go to the barangay hall. After some time, AAA was crying by the park fountain when Renato Galuga y Wad-as, who introduced himself as “Jun-jun,” approached and forcibly took her to a closed dark parlor at the market place. Ignoring her resistance and threats to kill her if she made noise, he raped AAA at knife-point.
Witnesses Joselito Borja and Mitchell Garlitos saw the accused pulling AAA towards the market and informed her parents. They found AAA and Galuga outside a restaurant, brought the accused to the police station, where AAA initially remained silent but later disclosed the rape incident to a lady officer.
At trial, the prosecution presented AAA, her parents, and the two witnesses. The accused presented his live-in partner and another witness who testified about the crowded state of the park where the alleged crime occurred, implying the improbability of the rape happening unnoticed.
The RTC found Galuga guilty of rape, sentencing him to reclusion perpetua without parole and ordered the payment of damages. On appeal, the CA affirmed with modifications to the damages awarded.
**Procedural Posture:**
1. **RTC Decision (November 15, 2011)**: Convicted Renato Galuga for rape, sentencing him to reclusion perpetua without parole and monetary damages.
2. **CA Decision (June 9, 2015)**: Affirmed RTC’s conviction but modified the damages awarded.
3. **Supreme Court**: Galuga appealed the CA decision, reiterating errors in the appreciation of evidence and credibility of testimonies.
**Issues:**
1. **Whether the RTC erred in convicting Renato Galuga of rape beyond reasonable doubt.**
2. **Whether the testimonies of the prosecution witnesses, despite perceived inconsistencies, were credible enough to support the conviction.**
3. **Whether the awarded damages were proper.**
4. **Whether the appellant’s plea to withdraw his appeal and apply for parole or probation holds merit.**
**Court’s Decision:**
The Supreme Court, finding no merit in the accused’s appeal, affirmed the decisions of the RTC and the CA with modifications on the awarded damages:
### Issue 1: Conviction Beyond Reasonable Doubt
The Court held that the testimony of AAA was clear, consistent, and compelling. The defendant’s denials were insufficient to discredit the vivid and straightforward account provided by AAA. The testimony of a rape victim, especially a minor, is usually compelling if positive and categorical, as was in this case.
### Issue 2: Credibility of Witnesses
The Court noted that minor inconsistencies do not detract from the general veracity of testimony. It underscored the principle that no standard behavioral response can be expected from victims of rape, particularly minors. Thus, AAA’s failure to immediately report the crime and silent demeanor initially did not discredit her account.
### Issue 3: Award of Damages
The Court modified the amount of damages awarded to align with prevailing jurisprudence: Php 75,000 each for civil indemnity, moral damages, and exemplary damages, plus 6% interest per annum from the finality of the decision until fully paid.
### Issue 4: Plea for Withdrawal of Appeal
The Court denied the plea for withdrawal of the appeal, explaining that as the sentence of reclusion perpetua makes the accused ineligible for parole under R.A. No. 9346 and barred from probation since he had already filed an appeal, contradicting the principles set in the Probation Law.
**Doctrine:**
1. **Credibility of Minor’s Testimony**: The testimony of a minor victim of rape, if positive and straightforward, is given considerable weight.
2. **Behavioral Responses of Rape Victims**: No definitive or standard reaction is expected from rape victims; trauma can manifest differently.
3. **Damages in Rape Cases**: Recent jurisprudence mandates specific sums for civil indemnity, moral, and exemplary damages plus interest.
4. **Exclusivity of Appeal and Probation**: Under the Probation Law, the pursuit of an appeal precludes the filing for probation.
**Class Notes:**
1. **Elements of rape involving minors** under Philippine law:
– Carnal knowledge by means of force, threat, or intimidation.
– Victim’s age below 18.
2. **Penalties**: Reclusion perpetua without parole eligibility when the victim is under 18.
3. **Credibility**: Positive identification and compelling testimony of the victim are critical.
4. **RA 9346 and The Probation Law**: Establish limitations on parole and probation for individuals sentenced to reclusion perpetua or having utilized appellate remedies.
**Historical Background:**
The case illustrates protections for minors under Philippine law, emphasizing stringent measures against sexual violence and abuse of minors, in line with R.A. No. 7610 and related amendments enhancing penalties under the Revised Penal Code for sexual offenses against children. It also highlights procedural strictness in the probation system intended to prevent abuses in the appeal process.
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