GR 175479; (July, 2008) (Digest)
G.R. No. 175479; July 23, 2008
THE PEOPLE OF THE PHILIPPINES, Appellee, vs. BIENVENIDO PAYOT, JR. y SALABAO, Appellant.
FACTS
The appellant, Bienvenido Payot, Jr., was convicted by the Regional Trial Court of the crime of rape against AAA, his 16-year-old sister-in-law. The prosecution’s evidence established that on July 17, 1999, AAA was asleep in her house when Payot, armed with a bolo, forcibly had carnal knowledge of her. AAA testified to the specific acts of force, the pain she felt, and the presence of the weapon that prevented her from resisting or shouting for help. Dr. Arsenia Referente, who examined AAA, corroborated the claim of sexual intercourse by finding two old healed hymenal lacerations consistent with penetration by an erect male organ.
The defense interposed an alibi, with Payot claiming he was at a neighbor’s house watching television and drinking tuba at the time of the alleged incident. He also suggested that AAA fabricated the charge due to resentment over his prior reprimands concerning her relationship with a lesbian friend. The trial court rejected the defense, giving full credence to AAA’s candid and consistent testimony, and found Payot guilty beyond reasonable doubt, sentencing him to reclusion perpetua.
ISSUE
Whether the guilt of the appellant for the crime of rape was proven beyond reasonable doubt.
RULING
Yes, the Supreme Court affirmed the conviction. The Court emphasized that in rape cases, the credibility of the victim’s testimony is paramount. AAA’s testimony was found to be clear, convincing, and consistent on material points, detailing the use of a bolo to intimidate her and the specific acts of sexual assault. The medico-legal findings, while indicating healed lacerations, were consistent with her account that the July 17 incident was her first sexual experience, as the healing process for such injuries can occur within days. The defense of alibi was inherently weak and could not prevail over AAA’s positive identification. The Court also found no ill motive for AAA, a young provincial lass, to falsely accuse her own brother-in-law of a grave crime that would expose her and her family to shame. The award of civil indemnity and moral damages was likewise sustained. The conviction was thus affirmed in toto.