GR 118986; (February, 2001) (Digest)
G.R. No. 118986 -89 February 19, 2001
People of the Philippines vs. Hernani Dichoson
FACTS
The accused-appellant, Hernani Dichoson, was convicted by the Regional Trial Court of Iloilo City for one count of acts of lasciviousness and three counts of rape committed against his young relative, Lelanie Dusaran. The complainant, born in 1970, was entrusted to the care of Dichoson’s household in 1979. She testified that the sexual abuses began in October 1981 with acts of lasciviousness and escalated to forcible sexual intercourse on multiple occasions in 1982, specifically on May 4, June 16, and July 12. She became pregnant as a result. Initially, out of fear and shame, she did not report the incidents and even implicated another person upon Dichoson’s instruction. She only revealed the truth to her father in 1983, leading to the filing of criminal cases.
The defense presented an alibi and denial. Dichoson claimed he was elsewhere during the alleged rapes and pointed to a hired hand, Tony Lopez, as the perpetrator. He asserted that Lopez and the complainant were in a romantic relationship and that Lopez had offered to marry her upon learning of the pregnancy.
ISSUE
The core issue is whether the prosecution proved the guilt of the accused-appellant for the crimes of acts of lasciviousness and rape beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction. The Court found the complainant’s testimony to be credible, straightforward, and consistent. It held that in rape cases, the credibility of the victim is paramount, and her testimony, if credible, is sufficient to sustain a conviction. The Court rejected the defense of alibi as weak and inherently unreliable, especially since it was not physically impossible for Dichoson to have been at the crime scene. His attempt to implicate Tony Lopez was unconvincing and unsupported by evidence. The Court also dismissed the argument that the delay in reporting the crime undermined the complainant’s credibility, ruling that such delay is not unusual for a young victim who was intimidated and ashamed. The subsequent pregnancy and birth of a child corroborated her claim of sexual intercourse. The Court thus upheld the trial court’s findings, emphasizing that the trial judge’s assessment of witness credibility is entitled to great respect. The penalties imposed by the RTC were affirmed.