GR 135559; (September, 2003) (Digest)
G.R. No. 135559, September 18, 2003
PEOPLE OF THE PHILIPPINES, APPELLEE, VS. MORENO OCUMEN Y MENDOZA ALIAS MORING, APPELLANT.
FACTS
On February 23, 1998, in Pozorrubio, Pangasinan, nine-year-old AAA was walking home from school when she was accosted by her uncle, appellant Moreno Ocumen. He forcibly pulled her into a forested area, removed her clothing and his own, and proceeded to have carnal knowledge of her against her will. AAA felt pain and cried. The act was witnessed from a distance by Juan Flores, who saw appellant on top of the naked child. AAA immediately reported the rape to her grandmother, leading to a police report and a medical examination. Dr. Francisco Llamas confirmed an old, healed laceration on AAA’s hymen consistent with sexual abuse.
The appellant denied the accusation, presenting an alibi that he was at home with family members making handicrafts at the time of the incident. He claimed the charge was fabricated by AAA’s father due to a prior familial dispute. The defense also presented AAA’s mother, Salvacion, who testified she noticed nothing unusual about her daughter’s behavior that day. The Regional Trial Court convicted appellant of qualified rape and imposed the death penalty.
ISSUE
Whether the prosecution proved the guilt of the appellant for the crime of qualified rape beyond reasonable doubt.
RULING
Yes, the Supreme Court affirmed the conviction. The Court found the testimony of the child-victim, AAA, to be credible, straightforward, and consistent. The testimony of an eyewitness, Juan Flores, who saw the appellant on top of the naked victim, corroborated her account. The medical findings, though noting an old laceration, were consistent with the victim’s disclosure of sexual abuse. The Court emphasized that the testimony of a young rape victim, when credible, is sufficient to sustain a conviction.
The defense of alibi was inherently weak and could not prevail over the positive identification by the victim and the eyewitness. The Court also dismissed the claim that AAA’s normal behavior after the incident discredited her story, noting that different people react to trauma in different ways, and such behavior does not negate the occurrence of rape. The qualifying circumstance of relationship (uncle and niece within the third civil degree) was duly alleged in the Information and proven during trial, warranting the imposition of the supreme penalty. However, pursuant to prevailing jurisprudence, the death penalty was reduced to reclusion perpetua, and the award of damages was modified accordingly.