G.R. No. L-70831 July 29, 1988
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. REYNALDO ALVAREZ y SORIANO, accused-appellant.

FACTS

The accused-appellant, Reynaldo Alvarez, was convicted of rape by the Regional Trial Court and sentenced to reclusion perpetua. The information alleged that on September 23, 1983, in Umingan, Pangasinan, he had carnal knowledge of Mary Grace Lacasandili, an 11-year-old minor, through force and intimidation. The prosecution evidence established that the victim was invited by the appellant’s stepdaughter to watch television at their house. After the stepdaughter left, the appellant approached the victim, forced her to lie down, removed her panties, and attempted to insert his penis into her vagina. The victim shouted for help but was threatened. The appellant desisted after two failed attempts. The victim did not immediately report the incident due to threats.
The crime was only revealed weeks later following a schoolyard quarrel among classmates about being rape victims, prompting an investigation by teachers. A medical examination conducted three weeks post-incident showed no physical signs of sexual abuse. The defense interposed alibi and claimed the case was fabricated because the appellant refused a loan to the victim’s mother. The trial court found the victim’s testimony credible and convicted the appellant.

ISSUE

Whether the trial court erred in convicting the accused-appellant based on the lone and uncorroborated testimony of the complainant and in not acquitting him on grounds of reasonable doubt.

RULING

The Supreme Court affirmed the conviction, modifying only the indemnity. The Court upheld the trial court’s assessment of the victim’s credibility, emphasizing that the findings of the trial court on witness credibility are accorded great weight and respect on appeal. The victim’s testimony was found to be clear, straightforward, and unwavering even under cross-examination. The Court rejected the appellant’s claim of improbability, noting that rape can be committed even in places where people might be nearby, and the failure to shout persistently does not negate rape when intimidation is present.
The defense of alibi was deemed weak and unsubstantiated, especially in light of the positive identification by the victim. The Court found it significant that the appellant failed to present his wife and stepdaughter as witnesses to corroborate his alibi, drawing an adverse inference from their absence. The alleged motive for fabrication—a denied loan—was dismissed as unproven and illogical, given the victim’s family’s comparatively better financial standing. The negative medical findings did not disprove rape, as the examination was conducted belatedly and an attempted, incomplete sexual act would not necessarily cause physical injuries. The penalty of reclusion perpetua was affirmed, but the moral damages were increased to Thirty Thousand Pesos (P30,000.00).