G.R. Nos. 105693-96 November 19, 1993
People of the Philippines, plaintiff-appellee, vs. Dindo Liquiran y Penuliar and Rodel de Vera y Ungia, accused-appellants.

FACTS

The accused-appellants, Dindo Liquiran and Rodel de Vera, were charged with four counts of statutory rape committed against Baby Rio Idos, an 11-year-old girl, on July 4 and July 7, 1991, inside the Calasiao Central School compound in Pangasinan. The informations alleged that the accused, conspiring and mutually helping one another, had sexual intercourse with the complainant by means of force and intimidation. The prosecution established that on the evening of July 4, 1991, the accused, who were known to the victim, offered to take her home but instead brought her to a school building where both undressed her and themselves. Rodel de Vera first had sexual intercourse with her while Dindo Liquiran held her hand, after which Dindo also had carnal knowledge of her. A similar incident occurred on July 7, 1991. The victim reported the incidents to her mother on July 8, 1991, and they filed a complaint with the police. A medical examination revealed healed hymenal lacerations. The defense consisted of alibi and denial, with Rodel claiming he was at home or at work and Dindo claiming he was driving his tricycle. Rodel’s mother also testified that the complaint was motivated by the victim’s mother’s suspicion that she was having an affair with the victim’s father. The Regional Trial Court convicted both accused of four counts of rape and sentenced each to four penalties of reclusion perpetua, plus indemnities.

ISSUE

Whether the trial court erred in giving full faith and credit to the prosecution’s testimonies and in finding both accused guilty beyond reasonable doubt of the crime of rape.

RULING

The Supreme Court affirmed the trial court’s decision in toto. The Court held that the gravamen of statutory rape under Paragraph 3, Article 335 of the Revised Penal Code is carnal knowledge of a woman below twelve years of age. The complainant’s positive and credible testimony, corroborated by the medical findings, sufficiently proved the commission of the crime. The Court found no merit in the defense’s arguments regarding the victim’s alleged “abnormal” behavior after the first incident, inconsistencies in her mother’s testimony, or the purported vengeful motive. The defense of alibi was properly rejected as the accused failed to prove it was physically impossible for them to be at the crime scene, given the proximity of their residences to the school. The medical certificate indicating healed lacerations did not negate the rape on July 7, as the doctor explained the lacerations could have been caused by prior sexual intercourse. The accused were found guilty beyond reasonable doubt as principals of the crime of statutory rape.