PEOPLE OF THE PHILIPPINES v.
RAMON FRANCIA Y NAVALTA
G.R. No. 208625. September 6, 2017
Summary: Statutory rape is committed when (1) the offended party is under 12 years of age and (2)
the accused has carnal knowledge of her, regardless of whether there was force, threat or
intimidation; whether the victim was deprived of reason or consciousness; or whether it was done
through fraud or grave abuse of authority. It is enough that the age of the victim is proven and that
there was sexual intercourse.
Topic: Criminal Law
Facts:
That on or about the 19th day of January 2005, the accused motivated by carnal lust and by means
of force, threat and intimidation, did, then and there willfully, unlawfully and feloniously have
carnal knowledge with [AAA], a girl eleven (11) years of age, a child within the meaning of R.A.
7610, by then and there inserting his private part into the latter's vagina, all against the latter's
will, which acts [sic] debases, degrades or demeans the intrinsic worth and dignity of the victim (a
child) as a human being.
The prosecution presented the child victim, AAA, who was then 11 years old and a Grade 6 student
at a public school in Nueve de Pebrero in Mandaluyong City. AAA testified that she lived with her
parents and five (5) siblings in Mandaluyong City near Cardinal Sin. AAA claimed that she knew
Francica because he was their neighbor.AAA testified that Francica was a good person because he
would sometimes give her money whenever he touched her.When asked how Francica touched
her, AAA answered that he licked her breasts and inserted his penis into her vagina.She claimed
that Francica started touching her sometime in March 2004 and that this went on many times. He
would sometimes even give her ₱50.00 after touching her.
ISSUE:
Whether or not the prosecution was able to prove beyond reasonable doubt that accused-
appellant was guilty of statutory rape as defined under Article 266-A(l )(d) of the Revised Penal
Code, as amended by Republic Act No. 8353, in relation to Republic Act No. 7610.
RULING:
YES. Rape under Article 266-A(l)(d) is also called statutory rape as "it departs from the usual
modes of committing rape." The child victim's consent in statutory rape is immaterial because the
law presumes that her young age makes her incapable of discerning good from evil. People v.
Gutierez explained the elements of statutory rape:
Statutory rape is committed when (1) the offended party is under 12 years of age and (2) the
accused has carnal knowledge of her, regardless of whether there was force, threat or
intimidation; whether the victim was deprived of reason or consciousness; or whether it was done
through fraud or grave abuse of authority. It is enough that the age of the victim is proven and
that there was sexual intercourse.
The defense did not dispute the fact that AAA was 11 years old at the time of the incidents. Her
birth certificate was presented into evidence before the trial court and was not questioned by the
defense. What only needs to be proven, therefore, is whether AAA and Francica had sexual
intercourse.
As shown by her testimony, AAA was able to narrate in a straightforward and categorical manner
what transpired between her and Francica. In a long line of cases, this Court has given full weight
and credence to the testimony of child victims, holding that their "[y]outh and immaturity are
generally badges of truth and sincerity." Compared to AAA's candid and categorical testimony,
Francica's defense of denial must fail. Imbo v. People emphasized that the self-serving defense of
denial falters against the "positive identification by, and straightforward narration of the
victim." This Court has likewise repeatedly held that the lone yet credible testimony of the
offended party is sufficient to establish the guilt of the accused.
