G.R. No. 124920 September 8, 1999
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ERNESTO ROSALES Y RIVERA, accused-appellant.

FACTS

Ernesto Rosales was convicted by the Regional Trial Court of Parañaque for the rape of Isabel dela Cruz, an eleven-year-old minor, and sentenced to reclusion perpetua. The prosecution’s evidence established that Isabel, who was unschooled and had run away from home, was staying with the Rosales family. On March 20, 1993, around 11:00 a.m., while Isabel was playing, Rosales called her to wash dishes. While she was washing, he poked a knife at her back, threatened to kill her if she shouted, undressed her, and then forcibly had sexual intercourse with her. She suffered pain and vaginal bleeding. Isabel confided in her friend Flordeliza a few days later, and on March 25, 1993, she was medically examined at the NBI. The medico-legal officer, Dr. Maximo L. Reyes, found a healing superficial hymenal laceration consistent with the forcible insertion of a penis. The defense presented alibi, claiming Rosales was with his wife at the time and that he first met Isabel on March 22, 1993. A defense witness, Dionisia Policarpio, testified she was at Rosales’s house giving birth on March 20, assisted by Rosales’s wife, and did not see Isabel, but she could not produce a birth certificate for her child.

ISSUE

Whether the prosecution proved the guilt of accused-appellant Ernesto Rosales for the crime of rape beyond reasonable doubt.

RULING

Yes. The Supreme Court affirmed the conviction but modified the damages. The Court found the testimony of the victim, Isabel dela Cruz, to be credible, straightforward, and categorical, detailing the rape without wavering. Her testimony was corroborated by the medical findings of a healing hymenal laceration consistent with sexual intercourse. The defense of alibi and denial was inherently weak and could not prevail over the positive identification by the victim. The Court noted that the victim’s status as a “stowaway” did not impair her credibility, and there was no evidence of ill motive for her to falsely accuse the appellant. However, the prosecution failed to sufficiently prove the victim’s minority due to the absence of a birth certificate; thus, the conviction was for simple rape under Article 335 of the Revised Penal Code, not statutory rape. The penalty of reclusion perpetua was affirmed. The Court modified the award of damages, ordering accused-appellant to pay an additional P50,000.00 as civil indemnity and P20,000.00 as exemplary damages, on top of the P50,000.00 moral damages awarded by the trial court.