People v. Ruel Velarde Alias Doloy Belarde

Summary

This case involves the rape conviction of Ruel Velarde alias Doloy Belarde for sexually assaulting 9-year-old AAA on November 2, 1999, in Barangay Maputi, Zumarraga, Samar. The Supreme Court affirmed the lower courts' findings that AAA was a credible witness despite minor inconsistencies in her testimony, which are normal for traumatic experiences involving child victims. The Court reiterated that hymenal rupture is not required for rape conviction under Article 266-A(1)(d) of the Revised Penal Code, which criminalizes carnal knowledge of a woman under 12 years old. The appellant's defenses of denial and alibi were rejected as insufficient against positive identification. The case is significant for reinforcing protections for child rape victims and clarifying that complete penile penetration is not required for rape conviction. The Court imposed reclusion perpetua and modified damages to include P30,000.00 exemplary damages to deter elder abuse of minors.