GR 124368; (June, 2000) (Digest)
G.R. No. 124368 ; June 8, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. HENRY DE GUZMAN y PASCUAL, accused-appellant.
FACTS
On October 30, 1994, thirteen-year-old Rosario Lian went to an abandoned house (“Kamalig”) in Noveleta, Cavite, with a friend. The accused-appellant, Henry de Guzman, approached them and asked to speak with Rosario. He led her to his nearby hut under the pretext of getting water. Once inside, he closed the door, kissed her, and threatened her with a bolo when she tried to shout. He tied her hands, removed her clothing and his own, and had carnal knowledge of her against her will. Afterward, he threatened to kill her if she reported the incident. Rosario later revealed the rape to her grandmother, leading to a medical examination and the filing of a complaint.
The defense presented a different narrative. Accused-appellant claimed he found Rosario and her boyfriend, Marjon, already inside his hut when he arrived there around 11:00 PM. He alleged he merely slept there while the couple stayed, and he denied any sexual assault. He presented an alibi, supported by a friend’s testimony, that he was elsewhere drinking earlier that evening.
ISSUE
The core issue is whether the prosecution proved the guilt of the accused-appellant for the crime of rape beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction. The Court emphasized that the credibility of the victim’s testimony is paramount in rape cases. Rosario’s detailed, candid, and consistent narration of the events, including the use of a bolo and the tying of her hands, was found credible and sufficient to establish the elements of rape through force and intimidation. Her conduct after the incident, such as immediately confiding in her grandmother, was consistent with that of a genuine victim. The medical findings of a healing hymenal laceration corroborated her claim of recent sexual intercourse.
The Court rejected the defense’s denial and alibi as weak and unsubstantiated. Alibi is inherently frail and must be supported by clear and convincing evidence of the physical impossibility of the accused being at the crime scene, which was not demonstrated. The accused-appellant failed to prove any ill motive for Rosario to falsely accuse him. The trial court’s assessment of witness credibility is accorded great respect, as it is in a better position to observe demeanor. Consequently, the Court upheld the penalty of reclusion perpetua and the award of moral damages.