GR 143704; (March, 2003) (Digest)
G.R. No. 143704 ; March 28, 2003
PEOPLE OF THE PHILIPPINES, appellee, vs. ALEX MANALLO, appellant.
FACTS
The victim, nine-year-old Rosaldiza Nabor, was washing clothes at a remote barangay reservoir on March 30, 1992. While walking home, she was suddenly grabbed by the appellant, Alex Manallo, a coconut gatherer employed by her parents. Manallo, who was naked and armed with a knife, dragged her to a grassy area, rendered her unconscious by punching her, and raped her. Upon regaining consciousness, Rosaldiza found herself naked, in pain, and with semen in her vagina. Manallo threatened to kill her family if she reported the incident. Rosaldiza immediately reported the rape to her mother, and they sought help from barangay officials and the police. A medico-legal examination confirmed fresh hymenal lacerations and the presence of motile sperm cells.
At his arraignment, Manallo pleaded not guilty. He posted a P50,000.00 bail bond after the trial court granted his motion for bail without a hearing. He subsequently failed to appear at trial and remained at large for six years before being re-arrested. At trial, he denied the rape and claimed he and Rosaldiza had been lovers for over a year, alleging she consented to sexual intercourse for money. The Regional Trial Court convicted him of rape and sentenced him to reclusion perpetua.
ISSUE
Whether the prosecution proved the guilt of the appellant for the crime of rape beyond reasonable doubt.
RULING
Yes, the Supreme Court affirmed the conviction. The Court found the testimony of the child victim to be credible, straightforward, and consistent. Her immediate reporting of the crime to her mother and authorities, coupled with the corroborative medico-legal findings of fresh hymenal lacerations and sperm cells, firmly established the fact of forcible sexual intercourse. The Court rejected the appellant’s defense of a romantic relationship as inherently incredible, noting the vast age difference and the victim’s tender age of nine, which renders consent legally impossible. The force and intimidation employed were evident from the appellant’s use of a knife, his physical assault, and his subsequent death threats.
The Court modified the award of damages, increasing the civil indemnity to P50,000.00 and awarding moral damages of P50,000.00 and exemplary damages of P25,000.00. It also strongly criticized the trial judge for granting bail without a hearing, which deprived the prosecution of due process and allowed the appellant to evade justice for six years, constituting gross ignorance of the law. The decision was affirmed with modifications as to the damages.