G.R. No. 118316 November 24, 1998
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ANTONIO DELA PAZ, JR., accused-appellant.

FACTS

Accused-appellant Antonio dela Paz, Jr. was charged with the rape of Merlinda Desacula, a 12-year-old girl suffering from severe mental retardation, with the intelligence of a three to four-year-old child. The prosecution’s evidence established that on June 25, 1991, the victim’s brother-in-law, Anecito Tabor, discovered the accused in flagrante delicto. Tabor testified that he saw the accused on top of the victim, with her panties pulled down and his pants lowered to his knees, in the act of sexual intercourse. Tabor apprehended the accused after a brief chase. A medical examination of the victim confirmed old, healed hymenal lacerations.
For his defense, the accused denied the rape and claimed he was mauled by Tabor and others over an alleged stolen fighting cock. He presented an alibi, stating he was at a billiard hall and a store earlier that evening, and offered a corroborating witness. The trial court convicted him of rape and sentenced him to reclusion perpetua, along with an order to pay moral damages.

ISSUE

The core issue is whether the trial court erred in convicting the accused based on the credibility of the prosecution witnesses and in its assessment of the medical evidence, particularly the significance of the victim’s old hymenal lacerations.

RULING

The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of witness credibility, giving it the highest respect as it is in the best position to observe witnesses firsthand. The positive, categorical, and consistent testimony of eyewitness Anecito Tabor, who caught the accused in the act, was found credible and sufficient to establish guilt beyond reasonable doubt. The Court ruled that the defense of denial and alibi, which was weakly corroborated, could not prevail over this positive identification.
Regarding the medical findings, the Court clarified that the presence of only old, healed hymenal lacerations does not negate the commission of rape. Citing medical jurisprudence and prior case law, the Court explained that a hymen may not lacerate during every sexual act due to various factors like distensibility, and old lacerations can result from causes other than prior intercourse. Thus, the absence of fresh lacerations was not exculpatory. The crime was deemed more despicable as it was committed against a mentally retarded minor. The penalty of reclusion perpetua and the award of damages were sustained.