G 78772 73; (May, 1991) (Digest)
G.R. Nos. 78772-73; May 23, 1991
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MATEO PATILAN, defendant-appellant.
FACTS
Jocelyn de Mesa, born on February 25, 1972, was sexually abused by the 19-year-old accused, Mateo Patilan, on three occasions in 1984 when she was only twelve years old. The incidents allegedly occurred on May 27, June 14, and June 28, 1984. The discovery was serendipitous when a relative witnessed the accused removing Jocelyn’s panty on June 28. Jocelyn initially refused to confess out of fear but later revealed the abuses to her mother. The barangay captain confronted the accused, who initially denied but later admitted to the acts at the police station, claiming he and Jocelyn were sweethearts and the acts were consensual.
Three criminal complaints for rape were filed. After preliminary investigation, the Municipal Trial Court found probable cause for the incidents on May 27 and June 28, but dismissed the complaint for June 14 for lack of prima facie evidence. Two corresponding Informations were filed with the Regional Trial Court (RTC). The RTC convicted the accused of two counts of rape, sentencing him to reclusion perpetua for each count. The accused appealed, arguing the trial court erred in giving credence to the complainant’s testimony and in convicting him.
ISSUE
Whether the accused is guilty beyond reasonable doubt of two counts of rape.
RULING
Yes, the Supreme Court affirmed the conviction. The Court found the testimony of the victim, Jocelyn, to be credible, straightforward, and consistent. She vividly recounted how the accused used a knife and threats of death to intimidate and force her into sexual intercourse. Her young age and the traumatic nature of the events lent credibility to her account, and her initial reluctance to speak out was consistent with the natural behavior of a traumatized child. The medico-legal report corroborated her testimony, showing a healed hymenal laceration compatible with sexual intercourse.
The Court rejected the accused’s defense of a sweetheart relationship and consent as a “fantastic tale” that defied common sense and human experience. It was inconceivable that a seven-year-old could initiate a romantic relationship or that a twelve-year-old would seduce a nineteen-year-old. The claim of consent was an attempt to trivialize a serious crime. The trial court correctly appreciated the qualifying circumstance of the victim’s minority, as she was under twelve years old at the time of the first rape in May 1984. The Supreme Court upheld the findings of the RTC, affirming the penalties imposed.