GR 124639; (February, 2001) (Digest)
G.R. No. 124639 . February 1, 2001
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. REYNALDO DE VILLA, accused-appellant.
FACTS
The prosecution established that in April 1994, in Pasig City, accused-appellant Reynaldo de Villa, then 67 years old and the uncle of the 12-year-old victim Aileen Mendoza by virtue of his marriage to her father’s sister, raped Aileen. She testified that she woke to find him on top of her, covering her mouth with a pillow and threatening to kill her. He succeeded in having carnal knowledge. The rape resulted in Aileen’s pregnancy, discovered in November 1994, prompting her to report the crime. Medical examination confirmed healed hymenal lacerations and her advanced pregnancy; she later gave birth in December. The defense interposed alibi, claiming accused-appellant was in Batangas during the alleged incident, and impotency due to age and a stomach ulcer, asserting he was physically incapable of sexual intercourse.
ISSUE
The core issue is whether the trial court erred in convicting accused-appellant of rape and imposing the death penalty, despite his defenses of alibi and impotency, and challenges to the victim’s credibility and the delay in reporting the crime.
RULING
The Supreme Court affirmed the conviction but modified the penalty to reclusion perpetua and awarded moral damages. The Court found the victim’s testimony credible and sufficient to establish rape. It ruled that a victim need not narrate every sordid detail; her categorical assertion, corroborated by medical evidence and the resulting pregnancy, suffices. The delay in reporting, common in rape cases due to trauma, does not undermine credibility. The defense of alibi was rejected as the distance between Pasig and Batangas was not insurmountable, making it physically possible for accused-appellant to be at the crime scene. The claim of impotency was deemed unconvincing without competent medical evidence; advanced age alone does not preclude sexual capability. However, the death penalty was reduced to reclusion perpetua because the information failed to allege with specificity the qualifying circumstance of relationship (that accused-appellant is the victim’s uncle by affinity), which is essential for imposing the supreme penalty under the law. The Court awarded P50,000 as civil indemnity and an additional P50,000 as moral damages, which are automatically granted in rape convictions without need for further proof.