GR 134266; (September, 2000) (Digest)
G.R. No. 134266; September 15, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MELENCIO BALI-BALITA, accused-appellant.
FACTS
The case stemmed from a complaint for rape filed by 11-year-old Ella Magdasoc against Melencio Bali-Balita, the common-law husband of her mother. Ella alleged that on August 26, 1997, in Quezon City, the accused, by means of force and intimidation and at knife point, undressed her, inserted his fingers into her private part, and thereafter had carnal knowledge with her against her will. The medico-legal examination confirmed Ella was in a non-virgin state, with deep healed hymenal lacerations, though no spermatozoa were found. The defense presented an alibi, claiming the accused was attending a wake with Ella’s mother at the time of the alleged incident. The trial court convicted the accused of statutory rape.
ISSUE
The core issue is whether the accused-appellant, Melencio Bali-Balita, is guilty beyond reasonable doubt of the crime of rape.
RULING
The Supreme Court affirmed the conviction. The Court emphasized that in cases of statutory rape under Article 335 of the Revised Penal Code, as amended, where the victim is under twelve years of age, the elements are simply: 1) that the accused had carnal knowledge of a woman; and 2) that the woman was below twelve years of age at the time. Proof of force, intimidation, or consent becomes immaterial. Ella’s credible and categorical testimony, corroborated by the medico-legal findings of her non-virgin state, sufficiently established carnal knowledge. The Court found no reason to deviate from the trial court’s assessment of Ella’s credibility, noting her testimony was straightforward and consistent. The defense of alibi was rightly rejected for being weak and unsubstantiated, especially as it was not physically impossible for the accused to have been at the crime scene. The positive identification by the victim prevails over a denial and alibi. The Information was also deemed sufficient as it clearly stated the accused’s name and his relationship to the victim, fulfilling the requirements under the Rules of Court. The penalty imposed by the trial court, reclusion perpetua, was affirmed, along with the award of civil indemnity and moral damages to the victim.