G.R. No. L-66970 February 28, 1985
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RODELIO GOZUM (GUZOM), accused-appellant.

FACTS

The prosecution evidence established that on the evening of November 11, 1974, 14-year-old housemaid Gloria P. Buna was sleeping in the bedroom of her employer, Rodelio Gozum, at his residence in Mandaluyong. Gozum’s common-law wife was out of the house. Gloria was awakened when Gozum, then 36 years old, placed himself on top of her, covered her mouth, removed her panty, and forcibly ravished her despite her resistance, tearing her dress in the process. The accused’s wife, Lourdes, discovered them in the bedroom and confronted Gozum, at which point Gloria fled. She reported the rape to the Mandaluyong police that same evening.
Gloria subsequently underwent a medical examination 87 days after the incident. The NBI medico-legal officer found that her hymen had a healed deep laceration and that her hymenal orifice could admit a tube 2.8 cm in diameter, confirming she was no longer a virgin. At trial, Gloria cried uncontrollably while testifying. The trial court found her unsophisticated and credible, noting she immediately reported the crime and later rejected offers from the wife and Gozum to settle the case for P500.

ISSUE

Whether the guilt of the accused for the crime of rape was proven beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction. The Court found no merit in Gozum’s appeal, which challenged the credibility of the prosecution’s version as incredible and highlighted alleged inconsistencies. The legal logic centered on the evaluation of evidence and witness credibility. The trial court’s assessment of Gloria’s demeanor as a shy, unsophisticated, and distraught 16-year-old witness during her testimony was accorded great weight. Minor inconsistencies in her testimony, a natural result of a protracted cross-examination of a young girl unaccustomed to trial, did not destroy her overall credibility.
The Court emphasized that the medical findings of a healed hymenal laceration conclusively established loss of virginity, rendering irrelevant Gozum’s argument about the improbability of pregnancy. The circumstantial evidence was compelling: Gozum was alone in the house with the sleeping victim, a situation the Court noted could arouse bestiality and temptation. Her immediate report to the police and steadfast refusal to accept a monetary compromise strongly corroborated her account. The defense’s denial and alternative explanation that the wife tore the dress were deemed unconvincing and insufficient to overturn the factual findings of the trial court. Thus, all elements of simple rape through force were proven beyond reasonable doubt.