GR L 35785; (May, 1974) (Digest)
G.R. No. L-35785 May 29, 1974
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DOMICIANO BAYLON, defendant-appellant.
FACTS
The complainant, thirteen-year-old Sugana Aspili, was on her way to school early in the morning of March 15, 1965, when the appellant, Domiciano Baylon, suddenly emerged from a thicket. He embraced her, covered her mouth, and pointed a knife at her chest, threatening to kill her if she shouted. He dragged her to a canal, hit her abdomen to subdue her resistance, forcibly removed her underwear, and succeeded in having carnal knowledge of her. After the act, the appellant fled. The victim, in pain and with a sticky substance on her thighs, ran home and immediately reported the rape to her parents.
The parents reported the incident to the barrio captain. The complainant was medically examined on the same day by Dr. Ofelia Agabin Flor, whose findings were consistent with recent sexual intercourse. The prosecution also presented the testimonies of the investigating police officer and the victim’s mother. The defense relied solely on alibi, claiming the appellant was elsewhere during the incident. The trial court convicted Baylon of rape and sentenced him to reclusion perpetua.
ISSUE
Whether the trial court erred in convicting the appellant of rape based on the credibility of the prosecution witnesses and in rejecting the defense of alibi.
RULING
The Supreme Court affirmed the conviction. The ruling emphasized the well-entrenched doctrine that the trial court’s assessment of witness credibility is accorded the highest respect, as it is in a superior position to observe demeanor and weigh testimonies. No fact or circumstance of weight was overlooked that would justify overturning this finding. The complainant’s detailed, consistent, and candid testimony, corroborated by the medical examination and her immediate reporting of the crime, established the elements of rape—carnal knowledge through force and intimidation.
The defense of alibi was correctly rejected for being inherently weak and unsubstantiated. It could not prevail over the positive identification by the victim. The Court also dismissed attempts to cast doubt on the commission of the rape, noting the natural reactions of the young victim and her parents. The crime was proven beyond reasonable doubt. The decision was affirmed with the modification that the appellant must pay an indemnity of P5,000.00 to the offended party.