G.R. No. 182457 ; January 30, 2013
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. ANTONIO BASALLO y ASPREC, Accused-Appellant.

FACTS

The accused-appellant, Antonio Basallo, was charged with the rape of ABC, his then 15-year-old housekeeper, on May 8, 1995, in Agoo, La Union. The prosecution alleged that Basallo, armed with a knife, forced ABC into a room on the second floor of his house and had carnal knowledge of her against her will. ABC did not immediately report the incident out of fear but later confided in her mother upon the discovery of her pregnancy, which led to the filing of the complaint. Basallo evaded arrest for over two years before being apprehended in August 1998.
During trial, ABC provided a detailed account of the assault, testifying that Basallo used a knife to intimidate her and prevent her from resisting or crying out. The defense, for its part, presented an alibi, claiming Basallo was at a different location attending to his sick mother at the time of the alleged crime. The defense also attempted to impugn ABC’s credibility by highlighting her delay in reporting and her continued work for the Basallo household for a week after the incident.

ISSUE

Whether the guilt of accused-appellant Antonio Basallo for the crime of rape was proven beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction. The Court found ABC’s testimony to be credible, straightforward, and consistent on the material points of the rape. The Court emphasized that in rape cases, the victim’s testimony, if credible, is sufficient to sustain a conviction. The delay in reporting was satisfactorily explained by ABC’s fear of the accused, who threatened to kill her and whom she knew to be a violent person. Her continued stay in his employ for a short period after the incident did not negate the rape, as it was a consequence of the same fear and intimidation that enabled the crime.
The Court rejected the defense of alibi as inherently weak and unsubstantiated by clear and convincing evidence. It failed to meet the requirement of proving the physical impossibility for Basallo to have been at the scene of the crime. The positive identification by the victim, who knew Basallo well as her employer, prevailed over the unsubstantiated alibi. The medical certificate, while not showing fresh physical injuries, was consistent with ABC’s account given the significant lapse of four months before her examination. The Court thus upheld the findings of the trial court and the Court of Appeals, modifying only the awarded damages by increasing the civil indemnity and moral damages and awarding exemplary damages in line with prevailing jurisprudence.