GR 127111; (February, 2001) (Digest)
G.R. No. 127111 . February 19, 2001.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. LUDOVICO BLAZO y MERSA, accused-appellant.
FACTS
The accused-appellant, Ludovico Blazo, was convicted by the Regional Trial Court of Quezon City for the rape of Susan Socuano, a ten-year-old girl, and sentenced to reclusion perpetua. The prosecution established that on November 25, 1994, while the victim was walking home through a cemetery, Blazo, a 52-year-old neighbor, forcibly dragged her to a kubol, threatened her with a knife, and had carnal knowledge of her against her will. The victim, out of fear due to Blazo’s threats to kill her parents, did not report the incident until mid-1996. A medical examination confirmed her non-virgin state and the presence of healed hymenal lacerations consistent with forcible penetration.
The defense consisted solely of Blazo’s testimony denying the accusation. He presented an alibi, claiming he arrived home from work at 9:00 PM on the date in question, and suggested the charge was fabricated due to a prior quarrel between his wife and the victim’s mother. The trial court found the victim’s testimony credible and convicted Blazo.
ISSUE
Whether the prosecution proved the guilt of the accused-appellant beyond reasonable doubt.
RULING
Yes, the Supreme Court affirmed the conviction. The Court held that the victim’s credible and categorical testimony, corroborated by medical findings, was sufficient to establish guilt. The delay in reporting the crime, spanning almost two years, was satisfactorily explained by the victim’s young age and her genuine fear of the appellant’s threats against her and her parents. The Court emphasized that in rape cases, the testimony of a victim, especially a child, is given full weight and credit when it is straightforward and consistent. The defense of denial and alibi, uncorroborated and inherently weak, could not prevail over the positive identification by the victim. The medical evidence, while not pinpointing the exact date of the violation, was consistent with the victim’s account of forcible sexual intercourse. The Court found no reason to overturn the trial court’s assessment of witness credibility. The penalty of reclusion perpetua was affirmed, and the award of moral damages was sustained.