GR 97475 76; (July, 1991) (Digest)
G.R. Nos. 97475-76; July 18, 1991
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DIOSCORO VILLAMAYOR y OCAMPO @ JESSIE, accused-appellant.
FACTS
The accused-appellant, Dioscoro Villamayor, was charged with Grave Threats and Rape. For Grave Threats, it was alleged that from October to November 1975 in Iriga City, he, with two unidentified companions, threatened to kill 13-year-old Aurea Nadal if she did not give him money, compelling her to hand over various sums totaling P100. For Rape, it was alleged that on November 11, 1975, Villamayor, armed with a knife and aided by his companions who acted as lookouts, had carnal knowledge of Aurea inside a building’s fire escape enclosure through force and intimidation. The victim testified to the repeated extortion and the detailed rape incident.
ISSUE
The core issue is whether the prosecution proved the guilt of the accused-appellant for the crimes of Grave Threats and Rape beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction. On the credibility of the complainant, the Court held that the testimony of a young rape victim is accorded full credence in the absence of evidence showing any ill motive to falsely accuse. The Court reasoned that the victim’s harrowing experience and the intimidation she suffered explain any minor inconsistencies or failure to recall every detail; one cannot expect a traumatic victim to remember all ugly specifics. The medical findings of fresh hymenal lacerations corroborated her account of a forcible defloration.
The Court rejected the defense of alibi. For alibi to succeed, it must be demonstrated as physically impossible for the accused to be at the crime scene. The appellant claimed he was in Buhi, Camarines Sur, but the Court noted this location was only 13 kilometers away from Iriga City, making his presence at the crime scene entirely possible. This defense cannot prevail over the victim’s positive and categorical identification of the appellant as her assailant. Finally, the Court addressed the procedural matter that the judge who decided the case did not hear the testimony, ruling that a judge can validly render judgment based on the complete trial transcripts and records. The guilt for both crimes was thus established beyond reasonable doubt.