G.R. No. 174098 , September 12, 2008
People of the Philippines, Plaintiff-Appellee, versus Reynaldo Teczon y Pascual, Accused-Appellant.

FACTS

On October 10, 2000, the 14-year-old complainant, AAA, was accompanying her aunt to school. While her aunt attended a meeting, AAA left to get refreshments. She was accosted by accused-appellant Reynaldo Teczon, who persistently invited her to his house. Upon her refusal, he pulled a fan knife, pointed it at her neck, and dragged her to a forested area. There, he undressed her and himself, kissed her, and had sexual intercourse with her for about twenty minutes. Afterward, he threatened to kill her if she reported the incident. AAA returned to school disheveled but initially concealed the assault from her schoolmates and teacher, claiming she had a fight.
The following day, AAA revealed the rape to her mother, who informed the school adviser. AAA identified Teczon as her assailant. A medical examination confirmed recent sexual intercourse and a vaginal laceration. Teczon was charged with rape. In his defense, he claimed he merely witnessed AAA having consensual sex with another young man on the same afternoon and that she fabricated the charge because he discovered them. He also alleged that boils near his groin made sexual intercourse impossible.

ISSUE

The core issue is whether the prosecution proved the crime of rape against accused-appellant beyond reasonable doubt, overcoming his defenses of denial and alibi.

RULING

The Supreme Court affirmed the conviction. The Court upheld the credibility of AAA’s testimony, which was clear, consistent, and candid on the material points of the rape. Her initial reluctance to immediately report the crime was deemed understandable given the direct death threat from the armed accused-appellant, and it did not undermine her credibility. The medical findings corroborated her account of a recent sexual assault.
The Court rejected Teczon’s defense as inherently weak and unsubstantiated. His claim of being a mere witness to AAA’s consensual act was a bare allegation unsupported by any credible evidence and was contrived to exculpate himself. His alibi regarding boils was conclusively negated by the testimony of his own witness, the examining physician, who stated that sexual intercourse was still medically possible. Denial cannot prevail over the positive and credible identification by the victim. The qualifying circumstance of minority (AAA being 14) and the aggravating circumstance of use of a deadly weapon were properly appreciated. The penalty of reclusion perpetua and the award of moral damages were sustained.