G.R. No. 132544 May 12, 2000
People of the Philippines, plaintiff-appellee, vs. Ireneo Dequito, accused-appellant.

FACTS

The accused-appellant, Ireneo Dequito, was convicted by the Regional Trial Court of Gumaca, Quezon, for the rape of his sister-in-law, Analiza Pidoc, then 15 years old. The prosecution evidence established that in July 1996, while Analiza was living under the custody of Dequito and her older sister, Dequito brought her to a coconut plantation in Barangay Montes Balaon to help with work. There, he forcibly had carnal knowledge of her on two occasions, threatening to abandon her sister if she revealed the assaults. Analiza eventually reported the rapes in September 1996, after confiding in an acquaintance. A medical examination confirmed hymenal lacerations.
The defense presented a denial and alibi. Dequito, corroborated by his common-law wife Analyn and a co-worker, claimed he was never alone with Analiza during the relevant period. He alleged the charge was fabricated after Analiza left their home, and he presented a letter purportedly from Analiza stating another man had deflowered her. Analyn testified she received this letter but did not confront her sister about its serious contents.

ISSUE

Whether the trial court erred in convicting the accused-appellant of rape despite the defense’s claim that the prosecution failed to prove his guilt beyond reasonable doubt and that the alleged incidents did not constitute rape.

RULING

The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment that the positive, credible, and categorical testimony of the victim, Analiza, prevailed over the accused’s bare denial and alibi. Her testimony on the use of force and intimidation was clear and consistent. The presence of her young brothers during one incident did not negate the rape, as they were too young to comprehend the act or provide protection. The medical findings corroborated her account of sexual intercourse.
The Court found the defense evidence unpersuasive. The alleged letter implicating another man was properly rejected; Analiza denied writing it, and Analyn’s claim of receiving it during a jest was deemed unnatural and incredible for such a grave matter. The delay in reporting was sufficiently explained by Analiza’s youth, dependence on the accused, his threats, and her sister’s dissuasion, which did not impair her credibility. Consequently, the prosecution proved guilt beyond reasonable doubt. The Court modified the damages, awarding an additional P50,000.00 as moral damages to the victim.