### Facts:
Juanito Garcia, also known as “Wapog,” was accused and later convicted for the statutory rape and acts of lasciviousness against AAA (a pseudonym to protect the victim’s identity), an 8-year-old girl and his cousin. The Regional Trial Court (RTC) of Calauag, Quezon, handled three separate criminal case informations: two counts of statutory rape (Criminal Case Nos. 3840-C and C-3838-C) and one count of acts of lasciviousness (Criminal Case No. 3839-C). Garcia pleaded not guilty to all charges.
AAA testified that Garcia sexually abused her on three consecutive days starting April 30, 2001. Additional witnesses included Rosalina Alcantara, who assisted in filing the complaint, and Dr. Florentina Agno Vergara, who confirmed AAA’s sexual abuse through medical examination. Garcia and his mother, Nancy Garcia, presented a defense of denial and insinuated malicious accusation due to a family land dispute.
The RTC convicted Garcia of one count of statutory rape and acts of lasciviousness but acquitted him for one of the statutory rape charges due to insufficient proof. Both Garcia’s conviction and the decisions on damages were later affirmed but modified by the Court of Appeals (CA).
### Issues:
1. Whether the prosecution sufficiently proved Garcia’s guilt for statutory rape and acts of lasciviousness beyond reasonable doubt.
2. Whether ill-motive on the part of the accuser’s family was a credible defense.
### Court’s Decision:
The Supreme Court found no merit in Garcia’s appeal. For statutory rape, it underscored that force, intimidation, or victim consent are irrelevant when the victim is below 12 years of age. The Court affirmed the following:
– The victim’s age was conclusively proven to be below 12 at the time of the incident.
– AAA’s consistent and corroborated testimony alongside medical evidence established Garcia’s guilt.
– The defense of denial and alleged ill-motive due to a family dispute was found insufficient to overturn the conviction.
For acts of lasciviousness, the Supreme Court also upheld the conviction, noting that Garcia’s actions towards AAA met the elements of the offense under Article 336 of the Revised Penal Code.
### Doctrine:
In statutory rape, the age of the victim conclusively presumes lack of consent when below 12 years of age, rendering the elements of force, threat, or intimidation immaterial. Testimonies of minor victims are accorded full weight, especially when corroborated by medical evidence. Denials and unsubstantiated claims of ill-motives are generally weak defenses against positive identification and testimonies of offenses involving sexual abuse.
### Class Notes:
– **Statutory Rape Elements:** Victim’s age below 12, identity of the accused, and occurrence of sexual intercourse.
– **Acts of Lasciviousness Elements:** Lewd acts under circumstances of force/intimidation, victim’s incapacity to consent, or victim under 12 years of age.
– **Key Statutes:**
– Article 266-B, Revised Penal Code for statutory rape.
– Article 336, Revised Penal Code for acts of lasciviousness.
– **Legal Applications:** Denial and alibi are weak defenses against the positive and credible testimony of the victim, especially minors. Family feuds or disputes are insufficient to establish ill-motive for false accusations in sexual abuse cases.
### Historical Background:
This case emphasizes the Philippine judicial system’s handling of sexual abuse crimes, particularly against minors. It demonstrates the principle of presuming no consent for victims under 12, a protective legal provision reflecting the societal and legal imperatives to shield children from sexual abuse. The case also provides insight into the evidentiary standards and procedural dynamics involved in prosecuting such sensitive cases in the Philippines.
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