G.R. No. 170342 ; September 18, 2009
ALLAN DIZON Y AQUI, Petitioner, vs. PEOPLE OF THE PHILIPPINES, Respondent.

FACTS

Petitioner Allan Dizon was charged with three counts of rape in the Regional Trial Court (RTC) of Olongapo City. The victim, AAA, was a 17-year-old with a harelip and cleft palate, who was illiterate and often left at home. The prosecution alleged that Dizon, a neighbor and relative by affinity, raped AAA on three occasions in 1996 and 1997, including an incident on February 20, 1997, where he used a knife to intimidate her. AAA later became pregnant, which was confirmed by a medical examination in April 1997, prompting her to reveal the rapes to her mother. The defense consisted solely of Dizon’s denial, claiming the charges were fabricated due to a family grudge.
The RTC convicted Dizon of one count of simple rape for the February 20, 1997 incident but acquitted him of the other two charges due to the victim’s vague testimony regarding the dates of those alleged rapes. The Court of Appeals affirmed the conviction but modified the damages awarded. Dizon appealed to the Supreme Court, arguing the prosecution failed to prove his guilt beyond reasonable doubt and questioning the credibility of AAA.

ISSUE

The core issue is whether the prosecution successfully proved the guilt of the petitioner for the crime of rape beyond reasonable doubt.

RULING

The Supreme Court denied the petition and affirmed the conviction. The Court upheld the factual findings of the lower courts, emphasizing that the assessment of the trial court on the credibility of witnesses is entitled to great weight. The Court found AAA’s testimony for the February 20, 1997 incident to be clear, convincing, and consistent. Her detailed account of the use of a knife, the application of cologne, and the subsequent threat established the elements of rape through force and intimidation. Her mental condition and illiteracy did not impair her credibility; instead, her straightforward narration, including minor inconsistencies, bolstered its spontaneity and truthfulness.
The Court rejected the defense of denial and alibi, which are inherently weak against positive identification. It found no ill motive for AAA, a relative, to falsely accuse Dizon. The fact that she was pregnant corroborated her claim of sexual intercourse. Regarding the two acquittals, the Court clarified that while the victim’s inability to specify exact dates for those incidents created reasonable doubt, it did not undermine her credibility for the clearly established February 20 rape. The failure to allege AAA’s minority in the information correctly meant the crime was properly classified as simple rape, not statutory rape. The awarded damages were affirmed as consistent with prevailing jurisprudence.