G.R. Nos. 93514-15, December 1, 1994
People of the Philippines vs. Ricardo Sabellina and Crisanto Baculio

FACTS

In the early morning of August 22, 1988, appellants Ricardo Sabellina (the victim’s cousin) and Crisanto Baculio, armed with a gun and a knife, roused the household of 13-year-old Evangeline Sabellina in Initao, Misamis Oriental. They forced the family downstairs at gunpoint, tied up her parents, and struck them. Crisanto then forcibly took Evangeline to a secluded area, threatened her with death, and raped her. Afterward, Ricardo took his turn and raped her in the same manner. The appellants then warned the family not to report the incident. Evangeline and her mother immediately reported the crime to a CHDF member, leading to the appellants’ arrest. A medical examination confirmed recent vaginal laceration and the presence of spermatozoa.
The defense presented an alibi, claiming they were engaged in a drinking session at Ricardo’s house throughout the night and early morning in question. They alleged the charge was fabricated due to a family grudge, as Ricardo was the common-law husband of Evangeline’s half-sister.

ISSUE

Whether the trial court erred in convicting the appellants of rape based on the credibility of the victim’s testimony and the sufficiency of the prosecution’s evidence.

RULING

The Supreme Court affirmed the conviction. The Court held that the victim’s clear, consistent, and candid testimony, corroborated by her mother’s account and the medical findings, constituted proof beyond reasonable doubt. The medical certificate, showing a fresh laceration and spermatozoa, strongly supported the claim of recent sexual intercourse. The Court dismissed the alleged inconsistencies in the testimonies (such as the exact date recall and which appellant held which weapon) as minor and inconsequential, not affecting the core narrative of the crime. Such minor discrepancies are common and may even enhance credibility by showing unrehearsed testimony.
The defense of alibi was rejected for being weak and unsubstantiated. The Court found it inconceivable that a mother would subject her young daughter to the stigma of a false rape charge merely due to a feud. Considering the victim’s tender age and the heinous nature of the successive rapes, the penalty of reclusion perpetua for each appellant was upheld. The Court, however, increased the moral damages awarded to the victim from P12,000.00 to P50,000.00 per appellant, or a total of P100,000.00, in line with prevailing jurisprudence for the rape of a young girl.