G.R. No. 93517 January 15, 1993
People of the Philippines, plaintiff-appellee, vs. Isabelo Guibao, accused-appellant.

FACTS

On January 2, 1986, a complaint was filed by six-year-old Lindy G. Escalante, assisted by her mother, charging appellant Isabelo Guibao with rape committed on November 5, 1985, in Barangay Hanigad, Surigao City. The appellant pleaded not guilty. The prosecution’s evidence established that on the morning of November 5, 1985, Lindy’s parents went to work, leaving her and her siblings under the care of an aunt. Lindy went out to play. Appellant Guibao, who lived nearby, called Lindy and offered her something to eat. Lindy went to his house. There, appellant removed his trousers, embraced Lindy, covered her mouth, and inserted his penis into her vagina, causing her pain and bleeding. Lindy described the penis as a “hairy piece of wood.” Her grandmother later found her bleeding and was told Lindy was “stabbed… with a black piece of wood with hairs.” Lindy’s mother brought her to the hospital. Dr. Erlinda P. Lago’s medical examination revealed contusions, lacerations on the labia majora, fourchette, and hymen, and a vaginal smear positive for spermatozoa. The defense consisted of appellant’s denial, claiming he was at his uncle’s house and did not know the victim. The trial court found appellant guilty beyond reasonable doubt of rape under Article 335 of the Revised Penal Code and sentenced him to reclusion perpetua, with indemnity and damages.

ISSUE

Whether the trial court erred in convicting the accused-appellant of the crime of rape based on the evidence presented.

RULING

The Supreme Court AFFIRMED the judgment of the trial court with MODIFICATION. The Court found no reason to disturb the trial court’s findings, emphasizing the credibility of the young victim’s testimony, which was straightforward, spontaneous, and natural. The testimony was corroborated by her mother and grandmother, and, most importantly, by the medical findings of spermatozoa and physical injuries consistent with rape. The Court held that denials, if unsubstantiated by clear evidence, cannot prevail over positive testimonies. The revelation of an innocent child whose chastity was abused deserves full credence, especially absent any motive to falsely testify. The award for moral damages was increased to P50,000.00.