G.R. No. 114144 February 13, 1997
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FLORENTINO ABAD, accused-appellant.

FACTS

The accused-appellant, Florentino Abad, was convicted by the Regional Trial Court of Tarlac for the rape of his thirteen-year-old granddaughter, Jenny Manaloto. Jenny testified that in April 1991, her grandfather summoned her to a room, pointed a bladed weapon at her neck, slapped her when she resisted, and proceeded to rape her. She alleged this occurred an average of four times a month for thirteen months. She only reported the incidents to her mother after an attack on May 19, 1992, leading to a medical examination which revealed a non-intact hymen but no other significant gynecological findings.
The accused-appellant denied the accusations, claiming Jenny left his house after being scolded and slapped for stealing rice. He argued that her failure to report the alleged attacks during the thirteen-month period and the absence of significant physical evidence from the medical examination rendered her testimony unreliable. The trial court found Jenny’s testimony credible and convicted Abad, sentencing him to reclusion perpetua and ordering him to pay indemnity and damages.

ISSUE

Whether the trial court erred in convicting the accused-appellant of rape based primarily on the complainant’s testimony, despite alleged inconsistencies and the absence of corroborative physical evidence.

RULING

The Supreme Court affirmed the conviction. The Court reiterated that in rape cases, the complainant’s testimony must be scrutinized with utmost caution, but a conviction can rest solely on such testimony if it is credible, consistent, and meets the test of credibility. The Court found the alleged inconsistencies raised by the defense—regarding the description of the weapon (interchanging “small bolo” and “knife”) and the relative positions during the incident—to be minor and inconsequential, especially given the complainant’s young age. Such discrepancies did not undermine her core narrative of sexual violation.
The Court emphasized that the trial court’s assessment of witness credibility is accorded high respect, as it had the direct opportunity to observe the complainant’s demeanor. The absence of pronounced physical injuries or fresh lacerations in the medical report does not negate rape, as complete penetration without significant trauma is possible. The Court found no ill motive for the granddaughter to falsely accuse her grandfather, who raised her since birth, of a grave crime that would subject her to public trial and him to lifelong imprisonment. Therefore, her testimony was deemed credible and sufficient to prove guilt beyond reasonable doubt.