G.R. No. L-40236, December 19, 1985
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. NICOMEDES TOLENTINO, accused-appellant.

FACTS

On November 16, 1969, in Bacoor, Cavite, fourteen-year-old Maria Ruby Jimenez went to the house of her cousin, Evelyn Jimenez, for academic assistance. While waiting, the accused-appellant, Nicomedes Tolentino, Evelyn’s 63-year-old grandfather, suddenly appeared. He mashed her breasts and, when she cried out, struck her twice in the stomach, rendering her unconscious. Upon regaining consciousness, Maria Ruby felt pain in her breasts and private parts, observed blood when urinating, and found her panty torn. Tolentino threatened to kill her if she reported the incident. She initially withheld the information from her mother but disclosed the rape to her father later that evening.
Subsequent events corroborated her account. She was medically examined days later by Dr. Isabel Sanchez, who found lacerations in her genitalia consistent with recent penetration by a hard object. Maria Ruby consistently identified Tolentino as her assailant on multiple occasions, reacting with fear in his presence. The defense presented an alibi, claiming Tolentino was at a cockpit in Las Piñas at the time, and attempted to attribute the crime to an unknown person through the testimony of his granddaughter, Evelyn.

ISSUE

The core issue is whether the prosecution proved beyond reasonable doubt that Nicomedes Tolentino committed the crime of rape against Maria Ruby Jimenez.

RULING

The Supreme Court affirmed the conviction. The ruling hinges on the credibility of the complainant’s testimony and the failure of the defense to present credible contrary evidence. The Court found Maria Ruby’s testimony to be clear, consistent, and credible. Her immediate disclosure to her father, her consistent identification of the appellant, and her physical and emotional reactions were deemed natural and truthful for a young barrio girl. The medical findings of recent lacerations provided strong corroboration of forcible intercourse.
The Court rejected the defense’s arguments. First, the alibi was untenable given the positive identification and the proximity of the cockpit to the crime scene, which did not make it physically impossible for Tolentino to have been present. The defense also failed to present any corroborating witness from the cockpit to substantiate the alibi. Second, the attempt to implicate another person through Evelyn Jimenez’s testimony was given little weight, as it was uncorroborated, presented belatedly, and came from a witness who was the appellant’s granddaughter and thus potentially biased. Third, the Court dismissed the claim that the complainant’s prior hospitalization for mental disturbance impaired her credibility, noting the trial court’s observation that she testified intelligently and truthfully. The uncorroborated testimony of a rape victim, if credible, is sufficient to sustain a conviction. The decision was modified only by increasing the civil indemnity to P30,000.00.