G.R. No. 135563 , September 18, 2003
People of the Philippines, Appellee, vs. Bobby Sanchez y Paguia, Appellant.

FACTS

On September 30, 1997, 17-year-old AAA was walking to school when her brother, appellant Bobby Sanchez, suddenly appeared, boxed her, and at knifepoint carried her to a sugarcane field. There, he gagged and tied her hands, inflicted more blows, and rendered her unconscious. Upon regaining consciousness, AAA felt pain in her vagina, found her uniform soiled and her underwear inverted, and realized she had been raped. Appellant threatened to kill their parents if she reported the incident. AAA eventually disclosed the rape to her parents that afternoon. A medico-legal examination revealed her hymen was “no longer appreciated,” which the doctor explained indicated a hard object had been inserted, causing its rupture.
The appellant denied the accusation, claiming it was fabricated by their father who harbored dislike for him. He presented an alibi, testifying that on the night before the incident, he was drunk at a disco and slept at his parents’ house until the afternoon of September 30. The Regional Trial Court convicted appellant of rape qualified by the use of a deadly weapon and by the relationship of brother and sister, sentencing him to death. The case was elevated to the Supreme Court on automatic review.

ISSUE

Whether the guilt of the appellant for the crime of rape was proven beyond reasonable doubt.

RULING

Yes. The Supreme Court affirmed the conviction but modified the awards of damages. The Court found AAA’s testimony to be credible, straightforward, and consistent. She provided a detailed account of the violent assault, the use of a knife, and the subsequent threats. The Court emphasized that in rape cases, the complainant’s testimony, if credible, is sufficient to sustain a conviction. The medico-legal findings, while noting an absence of spermatozoa and fresh lacerations, corroborated her claim. The doctor’s explanation that the hymen being “no longer appreciated” indicated penetration was deemed consistent with AAA’s account, especially given her menstruation at the time of the assault, which could explain the absence of sperm and fresh injuries.
The Court rejected the appellant’s defense of denial and alibi, which are inherently weak and cannot prevail over the positive identification by the victim. His claim of parental ill-will was unsupported by evidence. The qualifying circumstances of the use of a deadly weapon and the victim being the offender’s sister were duly proven. However, pursuant to prevailing jurisprudence, the penalty was reduced to reclusion perpetua as the death penalty law was deemed unconstitutional regarding the circumstance of relationship. The Court increased the civil indemnity to P50,000, moral damages to P50,000, and awarded P25,000 in exemplary damages.