G.R. No. 116808 April 11, 1997
People of the Philippines vs. Remus F. Busa Jr.

FACTS

On the evening of July 12, 1991, sixteen-year-old Marilyn Genes was walking home in Quezon City when a man, later identified as Remus Busa Jr., bumped her from behind, strangled her into unconsciousness, and dragged her to a grassy area. Upon regaining consciousness, she found herself bloodied, with her clothing in disarray and severe physical injuries, including a nearly severed right nipple and a lacerated vagina. She managed to walk and was found by her mother, who then sought immediate medical treatment. Shockingly, Banaue Children’s Hospital and later the Philippine General Hospital initially refused to treat Marilyn, directing them instead to the police and the NBI. Only after an NBI referral was she finally admitted to PGH for treatment.
The NBI investigation led to the filing of a rape complaint against Busa Jr. and two others. During trial, Marilyn positively identified Busa Jr. in court as her assailant, corroborated by her prior sworn statement describing a tall, dark, curly-haired man with a moustache who smelled of liquor. The medico-legal report documented extensive injuries consistent with violent sexual assault. The defense presented alibi, claiming Busa Jr. was elsewhere, but the trial court convicted him of rape.

ISSUE

Whether the prosecution proved the guilt of accused-appellant Remus Busa Jr. for the crime of rape beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of Marilyn’s credible and categorical testimony, which withstood rigorous cross-examination. Her positive in-court identification of Busa Jr. was deemed reliable, especially as it was consistent with her detailed description given to the NBI shortly after the traumatic incident. The defense of alibi was correctly rejected for being weak and unsubstantiated, especially when weighed against positive identification. The medico-legal findings provided powerful physical corroboration, proving carnal knowledge through force and the victim’s severe injuries. The Court found no ill motive for Marilyn to falsely accuse the appellant of such a grave crime. Consequently, the Court affirmed the penalty of reclusion perpetua and modified the civil liability, ordering Busa Jr. to pay Marilyn Genes Fifty Thousand Pesos (P50,000.00) as civil indemnity, in line with prevailing jurisprudence. The Court also strongly criticized the hospitals’ refusal to provide emergency medical treatment to the victim.