G.R. No. 155335; July 14, 2005
PEOPLE OF THE PHILIPPINES, Petitioner, vs. JESUS MACAPAL, JR., Respondent.

FACTS

The respondent, Jesus Macapal, Jr., was charged with the rape of Ligaya Sarino, a 23-year-old woman diagnosed with mild to moderate mental retardation, comparable to a 9-12 year old child. The prosecution alleged that in June 1996, in Agusan del Norte, Macapal dragged the victim to an isolated area, threatened her with a knife, and had carnal knowledge of her. The crime was revealed in December 1996 when the victim’s sister noticed her pregnancy. The victim initially executed an Affidavit of Desistance after entering into a Sworn Agreement for settlement, wherein Macapal’s family agreed to shoulder half the childbirth expenses. However, she later moved to rescind this agreement, claiming she was forced into it by police harassment.
The defense presented denial and alibi. Macapal claimed he first learned of the charge in December 1996 and suggested the victim’s boyfriend was responsible. A defense witness testified he saw the victim with her boyfriend in August 1996. Another witness, a barangay captain, claimed Macapal was working in a different barangay from May to August 1996. The Regional Trial Court convicted Macapal of rape and sentenced him to death. The Court of Appeals affirmed the conviction but modified the penalty to reclusion perpetua, prompting this automatic review.

ISSUE

The core issue is whether the guilt of Jesus Macapal, Jr. for the crime of rape was proven beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The Court found the victim’s testimony credible and consistent. As a mentally retarded individual, her detailed account of the rape—being waylaid, dragged, threatened with a knife, and sexually assaulted—was delivered in a straightforward manner and remained unshaken on cross-examination. Her mental condition did not impair her ability to recount the traumatic event accurately. The medical findings corroborated her testimony, confirming her pregnancy and the estimated conception period aligned with June 1996.
The defense of alibi was rejected. For alibi to prevail, the accused must prove not only his presence elsewhere but also the physical impossibility of being at the crime scene. The defense witness’s claim that Macapal was in a different barangay failed to establish this impossibility, as the locations were not shown to be prohibitively distant. The Court also gave no weight to the Affidavit of Desistance and the settlement agreement. Desistance does not automatically result in acquittal, especially in heinous crimes like rape. The victim’s subsequent recantation of the desistance, coupled with her vulnerable mental state and allegations of pressure from authorities, rendered the withdrawal of the complaint unreliable. The prosecution successfully proved all elements of rape through force and intimidation against a mentally incapacitated victim. The penalty of reclusion perpetua was upheld as proper.