### Facts:
The case involved Catalino Mingming y Discalso, accused and convicted of three counts of statutory rape committed against a ten-year-old girl, “AAA”, in Caloocan City. Mingming was arraigned on September 1, 1998, pleading not guilty. The proceedings took a detailed course with testimony from the prosecution and the defense’s reliance on denial and alibi from Mingming.
The incidents occurred in May and twice on June 29, 1998. AAA was living under the care of Alfonso Obispo, a neighbor to Mingming. The first incident took place when Catalino forcibly took AAA to a vacant lot, threatened her with a knife, and consummated the rape. AAA, initially silent due to threats, reported the subsequent rapes committed on June 29 to the Obispos, leading to police involvement and medical examination confirming sexual assault.
Through trial, the Regional Trial Court (RTC) convicted Mingming, a decision that the Court of Appeals affirmed with modifications related to damages awarded. Catalino filed for reconsideration, which was denied, proceeding to elevate the case to the Supreme Court under a mandatory appeal.
### Issues:
1. Whether AAA’s testimony was credible despite inconsistencies and the alleged delay in reporting the rape.
2. Whether the prosecution proved beyond reasonable doubt Catalino Mingming’s guilt for the three counts of statutory rape.
3. The appropriateness of the defenses of denial and alibi presented by Mingming.
### Court’s Decision:
The Supreme Court affirmed Catalino Mingming’s conviction for the first two counts of statutory rape but acquitted him on the third count due to insufficient evidence of actual sexual intercourse. The Court meticulously scrutinized the credibility of AAA’s testimony, the timelines, and Catalino’s defense.
1. The Court regarded AAA’s testimony as credible, dismissing arguments against it due to perceived inconsistencies and delay in reporting. It highlighted the societal and psychological barriers to immediately reporting rape and found justifiable reasons for AAA’s delay.
2. On Catalino’s defenses, the Court found them weak and unsupported by clear and convincing evidence. His alibi and denial could not overturn the positive identification and straightforward testimony of AAA regarding the rapes.
3. Regarding the third count of rape, the Court observed a lack of conclusive evidence proving sexual intercourse, leading to Mingming’s acquittal on this count.
### Doctrine:
Statutory rape under Philippine law does not require proof of force, intimidation, or consent, considering the victim below twelve years incapable of giving lawful consent. For conviction, the prosecution must establish the victim’s age, the identity of the accused, and the act of sexual intercourse.
### Class Notes:
1. **Statutory Rape**: A crime where consent is not a defense due to the victim’s age (below 12 years old). Elements include: victim’s age, accused’s identity, and act of sexual intercourse.
2. **Credibility of Witnesses**: In rape cases, the victim’s testimony holds significant weight if it is straightforward, credible, and consistent.
3. **Denial and Alibi**: Weak defenses against a positive identification and credible testimony unless supported by strong, clear, and convincing evidence.
4. **Evidence of Sexual Assault**: Lack of fresh hymenal lacerations does not negate sexual intercourse or rape; penetration or entry of the penis into the vagina, even minimal, constitutes rape.
5. **Delay in Reporting**: Not necessarily indicative of fabricated charges, considering the victim’s socio-psychological state and possible threats received.
### Historical Background:
The decision reflects the Philippine judiciary’s approach in handling rape cases, emphasizing the victim’s testimony’s importance and addressing common defenses utilized by accused persons. It underscores the judiciary’s sensitivity to the complexities surrounding reporting sexual crimes and the psychological impact on victims.
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