G.R. No. 112176 ; February 6, 1996
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. SANTOS CAÑADA, defendant-appellant.

FACTS

The prosecution established that on December 26, 1990, 12-year-old Loberiza Palaming attended a public dance in La Union, Castilla, Sorsogon. While seated alone, she was suddenly grabbed from behind by Santos Cañada, a CAFGU member, who dragged her to a nearby sampaloc tree. He tied her hands, gagged her mouth with a handkerchief, and threatened her with a gun. Despite her continuous struggle and resistance, Cañada overpowered her, removed her clothing, and succeeded in having carnal knowledge of her. After the act, Loberiza managed to box him before he fled. The incident was later reported, and a medical examination confirmed hymenal lacerations. The defense relied on alibi, with Cañada claiming he was sleeping at his home two kilometers away on the night in question, and he could not attribute any ill motive to the complainant for falsely accusing him.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused for the crime of rape beyond reasonable doubt, particularly in light of alleged inconsistencies in the victim’s testimony.

RULING

The Supreme Court affirmed the conviction. The Court meticulously addressed the alleged inconsistencies raised by the defense, finding them inconsequential and failing to undermine the credibility of the young victim. First, the discrepancy between her court testimony about being tied and gagged and her prior sworn statement was deemed natural, as ex-parte affidavits are often incomplete, especially for a naive 12-year-old responding only to specific questions. Second, the claim that she did not resist during her court testimony was misleading; the records clearly showed she actively kicked and boxed her assailant in defense. Third, the differing names of companions she provided referred to different contexts—those she went to the dance with versus those she was with at the dance hall—and did not constitute a material contradiction.
The Court emphasized that the testimony of a rape victim, particularly a minor, is accorded full credence when she demonstrates no ill motive to falsely testify. Loberiza’s detailed and consistent narration of the traumatic event, which withstood rigorous cross-examination, carried the hallmark of truth. The medical findings corroborated her claim of penetration. In contrast, the defense of alibi, uncorroborated by clear and convincing evidence and inherently weak, could not prevail over the positive identification by the victim. Thus, the trial court’s judgment imposing reclusion perpetua and an indemnity of P50,000.00 was sustained.