G.R. No. 105669 -70 October 18, 1994
People of the Philippines, plaintiff-appellee, vs. Jerry Rejano, accused-appellant.

FACTS

Two separate criminal complaints for rape were filed against appellant Jerry Rejano by complainant Maristela F. Santiago, a twelve-year-old girl, assisted by her mother Divina Santiago. The complaints alleged that Rejano raped Maristela in August 1990 and December 1990 in Hagonoy, Bulacan. The cases were consolidated. Maristela testified that the first rape occurred one evening in August 1990 in an open field where she was harvesting small crabs (talangka). Rejano, the only other person present, summoned her, grabbed her, forcibly removed her shorts and panty, pinned her down, and had carnal knowledge of her despite her resistance and screams. The next morning, Rejano threatened her not to tell anyone. The second rape occurred in December 1990 when Maristela went to Rejano’s house to borrow a bicycle. Rejano dragged her inside, brandished a knife, forcibly removed her shorts, and raped her on the floor, again warning her not to shout. Maristela did not immediately report the incidents due to fear. A medico-legal examination on February 4, 1991, revealed an old hymenal laceration consistent with penetration. The defense presented denial and alibi for the August incident, claiming Rejano was in Mindoro from July 24 to September 1, 1990. The trial court convicted Rejano of two counts of rape and sentenced him to reclusion perpetua for each count, plus indemnity.

ISSUE

Whether the trial court erred in convicting accused-appellant Jerry Rejano of two counts of rape based on the credibility of the complainant’s testimony and the evidence presented.

RULING

The Supreme Court affirmed the trial court’s decision. The Court held that the complainant’s testimony was credible, clear, and consistent, with convincing details that lent authenticity to her account. The fact that the judge who penned the decision was not the one who heard the evidence did not render it erroneous, as the Court independently reviewed the records and found the testimony credible. The medico-legal findings, showing an old hymenal laceration, corroborated the fact of sexual intercourse. The defense of alibi was weak and uncorroborated by clear and convincing evidence, and could not prevail over the positive identification by the complainant. The Court also found that the complainant’s failure to immediately report the rapes was sufficiently explained by the threats made by the appellant, which instilled fear in her. The appellant’s arguments regarding the complainant’s conduct were unavailing, as the Court recognized that different people react differently to traumatic events. The conviction was upheld.