GR 143432; (April, 2003) (Digest)
G.R. No. 143432 ; April 9, 2003
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. TERENCIO FUNESTO y LLOSPARDAS, accused-appellant.
FACTS
The accused-appellant, Terencio Funesto, was charged with the rape of eleven-year-old Louna Mae Quilantang on November 11, 1991. The prosecution evidence established that the victim, her mother Rosario, her sister, and Funesto all lived in a single-room house. On the night in question, while her mother was at a neighbor’s house, Louna Mae was awakened by a stabbing pain as Funesto, whom she recognized from a lit lamp, sexually assaulted her. He then threatened to kill her family if she reported the incident. The victim bled afterward, had a fever, and could hardly stand, but only disclosed the rape in February 1992 after Funesto was jailed for a separate rape charge against her sister. Medical examination confirmed a broken hymen and the presence of spermatozoa.
The defense presented an alibi and denial. Funesto claimed the charge was fabricated by Rosario after he rejected her alleged sexual advance. He also alleged that policemen tried to extort money from him to drop the case. The trial court found him guilty beyond reasonable doubt and sentenced him to reclusion perpetua, a decision he appealed.
ISSUE
The core issue is whether the prosecution proved the guilt of the accused-appellant for the crime of rape beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction. The Court emphasized that the credibility of the victim’s clear, candid, and consistent testimony, given despite her youth, prevails over the accused’s bare denial and unsubstantiated alibi. The medical findings, though conducted months later, corroborated her account of sexual violation. The Court found the delay in reporting the crime justified by the accused’s threats against the victim’s family, which instilled a well-grounded fear. The defense’s claim of extortion by the police was deemed a common and unsubstantiated ploy that did not weaken the prosecution’s case. The elements of rape—carnal knowledge of a woman under twelve years of age—were conclusively established. The penalty of reclusion perpetua was upheld, and the accused was ordered to pay civil indemnity and moral damages.