GR 130524; (June, 2001) (Digest)
G.R. No. 130524; June 20, 2001
PEOPLE OF THE PHILIPPINES, plaintiff and appellee, vs. RUDY MADIA, accused and appellant.
FACTS
The accused-appellant, Rudy Madia, was charged with four counts of statutory rape against Maria Aurora Fortunato, a ten-year-old girl suffering from epilepsy. The incidents occurred on July 1, 2, 3, and 9, 1995, in Barangay Agtongo, Romblon. In each instance, the appellant brought the victim to a dilapidated house or a forested area under the pretext of curing her ailment, removed her clothing and his own, laid beside her, and inserted his penis into her vagina. The victim pleaded for him to stop but he persisted. After each act, the appellant threatened her with bodily harm, causing her not to report the incidents immediately. The crimes were discovered after a neighbor informed the victim’s mother that she had seen the victim with the appellant. A medical examination revealed the victim’s hymen was ruptured. The appellant denied the charges, presenting an alibi that he was at home watching his grandchild or working on a table during the alleged times. The Regional Trial Court found him guilty beyond reasonable doubt of four counts of statutory rape and sentenced him to reclusion perpetua for each count, with damages.
ISSUE
Whether the trial court erred in convicting the accused-appellant of four counts of rape despite the prosecution’s alleged failure to prove his guilt beyond reasonable doubt, particularly citing the victim’s failure to immediately report the incidents.
RULING
The Supreme Court affirmed the conviction. The appeal was devoid of merit. The Court held that the victim’s failure to immediately report the rape incidents does not cast doubt on her credibility. Different people react differently to traumatic experiences, and there is no standard behavioral response. The victim, a naïve ten-year-old, could not be expected to possess the discernment to immediately report the assault, especially given the appellant’s threats of bodily harm. The Court noted that the charges were filed within the same month the rapes were committed, which is justified. The appellant’s defense of alibi was weak and could not prevail over the positive identification and credible testimony of the victim. The medical findings corroborated the victim’s account. The trial court’s decision was upheld, and the penalties and damages imposed were affirmed.