G.R. No. 132369 June 29, 1999
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. REMEGIO RUIZ, accused-appellant.

FACTS

The accused, Remegio Ruiz, was charged with the rape of fifteen-year-old Evelyn Violeta in Sta. Maria, Bulacan. The prosecution’s narrative, as testified to by Violeta, detailed that in the early morning of July 31, 1994, Ruiz forcibly entered her uncle’s house where she was sleeping. Armed with a screwdriver and a gun, he intimidated her, pushed her onto a bed, and proceeded to have carnal knowledge of her against her will. After the act, Violeta managed to escape and sought help at a nearby gas station from cashier Benigno de la Cruz, who confronted Ruiz. Violeta immediately reported the rape, and a subsequent NBI medico-legal examination confirmed the presence of recent genital trauma, though her hymen remained intact.
The defense presented a denial and alibi. Ruiz admitted being at Violeta’s house at the material time but claimed he only went there to inquire about her uncle’s tricycle fare, after which Violeta inexplicably ran away. He suggested the charge was fabricated following a failed extortion attempt by Violeta’s uncle. To support his claim of being a victim of a frame-up, he presented evidence of having been mauled by police upon his arrest.

ISSUE

The core issue is whether the prosecution successfully proved the guilt of the accused 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 clear, consistent, and categorical testimony, given in a straightforward manner and even including an emotional courtroom identification of her attacker, was paramount. This positive testimony prevailed over the accused’s bare denial and implausible alibi. The Court found no ill motive for the young victim to falsely accuse the appellant, and her immediate reporting of the crime lent further credibility to her account.
The medico-legal findings, while noting an intact hymen, were deemed consistent with the commission of rape. The expert testimony explained that an elastic hymen may not tear, and the documented abrasion at the posterior commissure constituted the “recent genital trauma” corroborative of forced sexual contact. The absence of spermatozoa did not negate rape, as completion of the sexual act with emission is not an essential element. The corroborating testimonies of the gas station cashier and the police investigator solidified the timeline of events and the victim’s conduct. Consequently, the elements of carnal knowledge through force and intimidation were established beyond reasonable doubt.