The Supreme Court established comprehensive guidelines for the Bench and Bar regarding the applicable laws, nomenclature of crimes, and imposable penalties for acts of lasciviousness, sexual assault, and rape, particularly when the victim is a minor, by reconciling R.A. No. 8353 (The Anti-Rape Law of 1997) which amended the RPC, and R.A. No. 7610 (Special Protection of Children Against Abuse, Exploitation and Discrimination Act). The Court held that Article 266-B of the RPC (imposing reclusion perpetua for rape) prevails over Section 5(b) of R.A. No. 7610 in cases of sexual intercourse with a child 12 years of age or below 18, but for sexual assault against a child under 12, the penalty under Section 5(b) of R.A. No. 7610 (reclusion temporal in its medium period) applies if higher than the RPC penalty.

The case arose from two separate incidents where the accused-appellant, Salvador Tulagan, sexually abused his nine-year-old neighbor, AAA. The first incident involved Tulagan inserting his finger into AAA's vagina (sexual assault), and the second involved Tulagan having sexual intercourse with AAA (statutory rape). These acts prompted the filing of criminal charges, leading to a legal battle that reached the Supreme Court, necessitating a clarification of the complex interplay between different penal laws concerning child sexual abuse.

• Sometime in September 2011, AAA, a nine-year-old minor, was peeling corn with her cousin when accused-appellant Salvador Tulagan, who lived near AAA's grandmother's house, approached her, spread her legs, and inserted his finger into her private part, causing her pain.
• On or about October 8, 2011, around 11:00 a.m., while AAA was playing with her cousin in front of Tulagan's house, Tulagan brought her into his house, told her to keep quiet, lie down, and removed her shorts and panties. He then undressed himself, kissed AAA's cheeks, and inserted his penis into her vagina, causing her pain. AAA cried as Tulagan held her hands.
• AAA did not immediately report these incidents.
• On October 17, 2011, BBB, AAA's aunt, noticed a man (Tulagan) looking at AAA. Later, after AAA returned from an outside bathroom, BBB questioned her. AAA confessed about the abuses committed by Tulagan, whom she referred to as "Badong."
• A genital examination conducted by Dr. Brenda Tumacder revealed a healed laceration at the 6 o'clock position in AAA's hymen and a dilated vaginal opening, which was not normal for a nine-year-old.
• Tulagan, for his defense, denied knowing AAA well but admitted living about five meters from her grandmother's house. He claimed that during September 2011, he was busy gathering banana leaves. He also alleged a prior misunderstanding between his mother and AAA's grandmother.

• Accused-appellant Salvador Tulagan argued that the Court of Appeals erred in giving weight and credence to the allegedly inconsistent testimony of the minor victim, AAA.
• Tulagan contended that the prosecution failed to prove his guilt beyond reasonable doubt, asserting that AAA's testimony was fraught with inconsistencies and lapses that affected her credibility.
• Tulagan imputed ill motive on the part of AAA's grandmother for the filing of the charges.
• Tulagan raised the defense of denial and alibi, claiming he was elsewhere during the commission of the crimes.

• The People of the Philippines, through the Office of the Solicitor General, maintained that the trial court and the Court of Appeals correctly found AAA's testimony credible, straightforward, and unwavering.
• The prosecution argued that all the elements of sexual assault and statutory rape were duly established beyond reasonable doubt.
• The prosecution contended that minor inconsistencies in AAA's testimony do not diminish her credibility but rather bolster it by discounting a rehearsed testimony.
• The prosecution asserted that AAA's positive identification of Tulagan as the perpetrator prevails over his defenses of denial and alibi, especially since Tulagan failed to prove physical impossibility of being at the crime scene.

• Whether the Court of Appeals erred in affirming the conviction of accused-appellant Salvador Tulagan for sexual assault and statutory rape despite alleged inconsistencies in the victim's testimony.
• How to reconcile the provisions on Acts of Lasciviousness, Rape, and Sexual Assault under the Revised Penal Code (RPC), as amended by R.A. No. 8353, with Sexual Intercourse and Lascivious Conduct under Section 5(b) of R.A. No. 7610, particularly concerning the nomenclature of the crime, imposable penalties, and damages based on the victim's age and circumstances.

• The Supreme Court denied the appeal and affirmed Tulagan's conviction with modifications to the nomenclature of the crime in SCC-6210, the penalty imposed, and the damages awarded in both cases.
• The Court found AAA's testimony credible and sufficient for conviction, reiterating that factual findings of trial courts, especially when affirmed by the CA, are generally accorded great weight. Minor inconsistencies do not negate credibility if the testimony is consistent on material points.
• The Court extensively discussed the interplay between R.A. No. 8353 (Anti-Rape Law of 1997) amending the RPC, and R.A. No. 7610 (Special Protection of Children Against Abuse Act).
• For sexual assault (inserting finger into vagina) against AAA (9 years old), the proper nomenclature is "Sexual Assault under paragraph 2, Article 266-A of the RPC in relation to Section 5(b) of R.A. No. 7610." The penalty should be reclusion temporal in its medium period as provided by Sec. 5(b) of R.A. 7610, because the victim was under 12.
• For statutory rape (penile penetration) against AAA (9 years old), Tulagan is guilty under Article 266-A(1)(d) in relation to Article 266-B of the RPC, penalized by reclusion perpetua.
• The Court clarified that if acts constituting sexual assault under Art. 266-A(2) RPC are committed against a victim under 12, the penalty under Sec. 5(b) of R.A. No. 7610 (reclusion temporal medium) applies, not the prision mayor under RPC, as R.A. 7610 provides for a higher penalty in such specific instances.
• The Court emphasized that Article 266-B of the RPC (reclusion perpetua for rape) must prevail over Section 5(b) of R.A. No. 7610 when sexual intercourse is committed with a child 12 years old or below 18, as R.A. 8353 is the more recent and specific law on rape penalties, providing stronger deterrence.
• The Court provided a comprehensive table outlining the applicable laws, designation of crimes, and imposable penalties for acts of lasciviousness, sexual assault, and rape based on the victim's age and circumstances (e.g., if exploited in prostitution or other sexual abuse - EPSOSA).
• Damages were modified: For Sexual Assault (SCC-6210), P50,000 each for civil indemnity, moral, and exemplary damages. For Statutory Rape (SCC-6211), P75,000 each for civil indemnity, moral, and exemplary damages. All damages to earn 6% interest per annum from finality until fully paid.

• Credibility of Child Victim's Testimony — Testimonies of child-victims are normally given full weight and credit, as young girls are unlikely to fabricate sordid tales of sexual abuse due to the shame and trauma involved. Applied here to uphold AAA's testimony despite minor inconsistencies and delayed reporting.
• Defense of Alibi and Denial — Alibi and denial are inherently weak defenses and cannot prevail over the positive and credible testimony of the prosecution witness, especially when the accused fails to prove physical impossibility of being at the crime scene. Applied to reject Tulagan's defenses.
• Statutory Construction: Reconciliation of Statutes — Statutes must be construed and harmonized with other statutes to form a uniform system of jurisprudence. If irreconcilable, the later enactment generally prevails. The Court endeavored to harmonize R.A. 8353 and R.A. 7610.
• Statutory Construction: Specific vs. General Law — In case of conflict, a special law prevails over a general law regardless of dates of enactment. However, the Court also considered R.A. 8353 as more particular on rape penalties.
• Statutory Construction: Legislative Intent — The primary rule is to ascertain and give effect to the legislative intent. The Court analyzed legislative deliberations to understand the purpose behind R.A. 8353 and R.A. 7610.
• EPSOSA (Exploited in Prostitution or Subjected to Other Sexual Abuse) — A qualifying circumstance under R.A. 7610, Section 5, which affects the applicable law and penalty for sexual offenses against children. The Court clarified its application based on the victim's age and the nature of the act.
• Civil Indemnity ex delicto — Mandatory award in crimes like rape, representing compensation for the injury caused, distinct from other damages. Awarded in this case.
• Moral Damages — Awarded to compensate for physical suffering, mental anguish, serious anxiety, etc., resulting from the crime. Awarded in this case.
• Exemplary Damages — Awarded in criminal cases as a deterrent or to set a public example, especially when aggravating circumstances are present or the crime is heinous. Awarded in this case.
• Doctrine of Implied Repeal — Repeals by implication are not favored. A law is repealed by a later law only if there is an irreconcilable inconsistency. The Court found that R.A. 8353 did not wholly repeal relevant sections of R.A. 7610 or Art. 336 of the RPC but modified their application.

• "For the guidance of the Bench and the Bar, We take this opportunity to reconcile the provisions on Acts of Lasciviousness, Rape and Sexual Assault under the Revised Penal Code (RPC), as amended by Republic Act (R.A.) No. 8353 vis-a-vis Sexual Intercourse and Lascivious Conduct under Section 5(b) of R.A. No. 7610, to fortify the earlier decisions of the Court and doctrines laid down on similar issues, and to clarify the nomenclature and the imposable penalties of said crimes, and damages in line with existing jurisprudence."
• "It is basic in statutory construction that in case of irreconcilable conflict between two laws, the later enactment must prevail, being the more recent expression of legislative will. Indeed, statutes must be so construed and harmonized with other statutes as to form a uniform system of jurisprudence, and if several laws cannot be harmonized, the earlier statute must yield to the later enactment, because the later law is the latest expression of the legislative will. Hence, Article 266-B of the RPC must prevail over Section 5(b) of R.A. No. 7610." (Specifically referring to rape by carnal knowledge where victim is 12 years or older but below 18).
• "If the lawmakers disagreed with our interpretation, they could have easily amended the law... and their silence could only be construed as acquiescence to our rulings."

• Dimakuta v. People — Referenced extensively for its discussion on the interplay between R.A. 7610 and Art. 266-A RPC, particularly that the offender should be liable under R.A. 7610 if it provides a higher penalty for lascivious conduct against a child victim, compared to sexual assault under RPC. The current ruling refines and builds upon Dimakuta.
• Quimvel v. People — Cited for its statutory construction analysis of Section 5(b) of R.A. 7610, particularly the application of its provisos based on the victim's age. The current ruling further clarifies the principles from Quimvel.
• People v. Caoili — Referenced for its guidelines on designating offenses and determining penalties for lascivious conduct under R.A. 7610 based on the victim's age. The current ruling adopts and expands upon Caoili's framework.
• Malto v. People — Discussed and clarified. While Malto stated that consent is immaterial in cases under Sec. 5, Art. III of R.A. 7610, the current ruling refines this by stating consent is material if the victim is 12-17 years old (unless EPSOSA applies), but immaterial if under 12 (statutory rape/lasciviousness).
• People v. Jugueta — Used as the basis for standardizing the amounts of civil indemnity, moral, and exemplary damages awarded in criminal cases, including rape and homicide, based on the imposable penalty.
• Amployo v. People — Cited for its broad definition of "lewd" conduct in relation to acts of lasciviousness.
• People v. Garcia — Cited for the principle that testimonies of child-victims are normally given full weight and credit.
• Olivarez v. Court of Appeals — Referenced in the dissenting opinions and discussed by the ponencia regarding the interpretation of "exploited in prostitution or subjected to other sexual abuse" under RA 7610.
• People v. Abay and People v. Pangilinan and People v. Tubillo — Clarified by the ponencia to streamline the prosecution process when elements of both RPC rape and RA 7610 child abuse are present, emphasizing that the focus should be on the specific elements alleged and proven rather than a forced choice based on "coercion and influence" vs. "force and intimidation."

• Revised Penal Code (RPC), Article 266-A (Rape; When and How Committed) — Defines rape by sexual intercourse and rape by sexual assault. Central to the charges against Tulagan and the Court's discussion on nomenclature and elements.
• Revised Penal Code (RPC), Article 266-B (Penalties for Rape) — Prescribes the penalties for rape defined under Art. 266-A. Applied in determining Tulagan's sentence for statutory rape.
• Revised Penal Code (RPC), Article 336 (Acts of Lasciviousness) — Discussed in relation to its interplay with R.A. 7610 and R.A. 8353, particularly for acts not amounting to rape by sexual assault but are lascivious in nature. The Court clarified its continued applicability.
• Republic Act No. 7610 (Special Protection of Children Against Abuse, Exploitation and Discrimination Act), Section 5(b) — A core provision analyzed, penalizing sexual intercourse or lascivious conduct with a child exploited in prostitution or subject to other sexual abuse. Its provisos regarding victims under 12 years old were key to the ruling.
• Republic Act No. 7610, Section 10 (Other Acts of Neglect, Abuse, Cruelty or Exploitation) — Referenced by dissenting opinions and discussed by the ponencia regarding the legislative intent to increase penalties for crimes against children.
• Republic Act No. 8353 (The Anti-Rape Law of 1997) — Amended the RPC provisions on rape (formerly Art. 335, now Arts. 266-A to 266-D). Its effect on R.A. 7610 and Art. 336 RPC was a major point of reconciliation.
• Rules and Regulations on the Reporting and Investigation of Child Abuse Cases (IRR of R.A. 7610), Section 2(g) and 3(h) — Defines "sexual abuse" and "lascivious conduct" respectively, which were used by the Court in interpreting R.A. 7610.
• 1987 Constitution, Article XV, Section 3(2) — Cited by the ponencia regarding the State's duty to protect children from all forms of neglect, abuse, etc., to support the interpretation of R.A. 7610 as providing broad protection.

• Justice Perlas-Bernabe — Agrees with the conviction but posits a "limited view" on the application of R.A. 7610, Section 5(b), arguing it only applies when the child-victim is "exploited in prostitution or subject to other sexual abuse" (EPSOSA). She believes R.A. 7610 fills gaps in the RPC by dispensing with the need to prove lack of consent when EPSOSA is present, and highlights incongruencies in penalties if R.A. 7610 is applied broadly.
• Justice Leonen — Concurs in the result (conviction). Reiterates his opinion from People v. Caoili that nonconsensual insertion of a finger into another's genitals is rape by carnal knowledge under Article 266-A, paragraph 1 of the RPC, not merely sexual assault. He also maintains his view from Quimvel v. People that Article 336 of the RPC has been rendered ineffective by R.A. 8353. He criticizes the traditional concept of rape being tied to "unwanted procreation."

• Justice Caguioa (Concurring and Dissenting Opinion) — Concurs partly in the result but dissents from the ponencia's reconciliation of R.A. 7610 and the RPC. He argues that R.A. 7610, Section 5(b) applies only in specific and limited instances where the victim is a child "exploited in prostitution or subjected to other sexual abuse" (EPSOSA). For all other cases of sexual abuse against children, the RPC, as amended by R.A. 8353, should apply. He criticizes the ponencia's approach of choosing the law based on which provides a higher penalty as a violation of due process and an improper exercise of judicial legislation. He submits a flowchart for a simpler application of the laws based on the presence or absence of the EPSOSA element.