GR 133741; (October, 2001) (Digest)
G.R. Nos. 133741-42; October 26, 2001
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. LINO VILLARUEL, accused-appellant.
FACTS
The accused-appellant, Lino Villaruel, was charged with two counts of rape committed on October 9 and 10, 1993, against Jennylinda Pagayona, a girl below twelve years old. The prosecution evidence established that on the night of October 9, 1993, while the victim was alone in her house, the appellant entered, threatened her with a knife, and sexually assaulted her. He performed various sexual acts, including vaginal and anal intercourse, and threatened to kill her and her family if she reported the incident. The victim managed to identify the appellant as he left. She immediately reported the rape to her relative and the police. A medical examination conducted by Dr. Perseverando Tangug revealed mucosal irritation in her vaginal opening but an intact hymen. The defense presented Dr. Rudolf Baladad, who testified that mucosal irritation could have other causes and that the intact hymen indicated no penetration. The appellant denied the charges, claiming the complaint was fabricated due to a prior incident where he slapped the victim for cursing him.
ISSUE
The core issue is whether the guilt of the accused-appellant for two counts of rape was proven beyond reasonable doubt, particularly in light of the medical finding of an intact hymen.
RULING
The Supreme Court affirmed the conviction. The Court held that the medical finding of an intact hymen is not indispensable for a rape conviction. The credible and categorical testimony of the victim, who was a minor, is sufficient to establish the crime. The Court found the victim’s testimony to be clear, consistent, and convincing in detailing the sexual assaults and the threats made by the appellant. Her immediate reporting of the incident bolstered her credibility. The defense of denial and alleged ill motive was deemed weak and unsubstantiated. The Court explained that in rape cases, the testimony of the victim is the single most important evidence. The fact that the victim was below twelve years old at the time of the commission of the crime made the rape qualified, warranting the penalty of reclusion perpetua. The award of moral damages was also sustained. The defense’s reliance on the intact hymen was misplaced, as complete penetration of the hymen is not required; mere entry of the male organ into the labia of the female organ constitutes carnal knowledge.