G.R. No. 102336 January 27, 1994
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JULIONITO OBEJAS @ “Juling”, accused-appellant.

FACTS

Rosalie Maat, a 12-year-old fourth grader, accused Julionito Obejas, the 37-year-old common-law husband of her mother Sonia Maat, of raping her on the night of August 2, 1990. According to Rosalie, she and Obejas went out around midnight in Barangay Magsaysay, Dulag, Leyte, to trap birds. At the site, after finding no birds, Obejas laid his jacket on the ground, took her spear, undressed, and ordered her to undress. He then pushed her to the ground, kissed her, mounted and penetrated her, and boxed her thighs. Rosalie resisted by biting his mouth. She felt pain and a sticky substance in her vagina. After releasing her, Obejas threatened to kill her and her family if she complained. She went home, cleaned herself, and changed her underwear. Rosalie did not immediately report the incident due to fear. Eight days later, on August 10, 1990, she revealed the rape to her grandmother, Liberata Gualberto, who took her for a medical examination at the Tacloban City Medical Center. Dr. Azucena Mirambel found a partly healed hymenal laceration. The grandmother then reported the matter to the police, and a complaint was filed. Obejas denied the charge, claiming he was asleep with Sonia Maat at the time and that Rosalie was living with her grandmother in San Jose, Tacloban City, kilometers away. The Regional Trial Court of Tacloban City, Judge Pedro S. Espina presiding, found Obejas guilty of rape and sentenced him to reclusion perpetua and to pay P50,000.00 as civil indemnity.

ISSUE

Whether the accused-appellant, Julionito Obejas, is guilty beyond reasonable doubt of the crime of rape.

RULING

The Supreme Court affirmed the decision of the Regional Trial Court, finding the accused-appellant guilty of rape. The Court rejected Obejas’s defenses of alibi and consensual intercourse. His alibi was deemed inherently weak and unsubstantiated, as it was not corroborated by Sonia Maat or other evidence. The claim of consensual intercourse was also rejected, considering Rosalie’s age of 12, the moral ascendancy Obejas held as her “step-father” (whom she called “Tatay”), and the force and intimidation employed, including being armed with a bolo and taking her spear. The Court found Rosalie’s conduct during and after the rape understandable given her age, inexperience, and the influence of her attacker. The delay in reporting was due to fear, and the charge was not shown to be motivated by malice. The absence of spermatozoa was explained by the eight-day lapse before examination and Rosalie wiping herself afterward, while the hymenal laceration constituted physical evidence of defloration. The Court upheld the penalty of reclusion perpetua and the increased civil indemnity of P50,000.00, noting the particular reprehensibility of rape committed against a child. The appeal was dismissed.