GR 206768; (December, 2014) (Digest)
G.R. No. 206768; December 3, 2014
People of the Philippines, Plaintiff-Appellee, vs. Leonardo Castrodes, Accused-Appellant.
FACTS
On April 17, 2000, in San Miguel, Bohol, the 15-year-old victim AAA was gathering firewood in a coconut plantation. The accused-appellant, Leonardo Castrodes, suddenly appeared, took her bolo, and carried her under a coconut tree. Threatened with the bolo, AAA was forced to lie down. Castrodes kissed her, caressed her breasts, removed her shorts and panty and his own clothing, and succeeded in inserting his penis into her vagina despite her resistance, causing her pain. After the act, he threatened to kill her and anyone she told. AAA reported the rape to her uncle CCC on April 26, 2000, after he found her crying. The matter was reported to barangay officials, and AAA was medically examined. The defense presented an alibi, claiming Castrodes was working on a farm with his cousin Jovenciano Castrodes the entire day of the incident. The Regional Trial Court convicted Castrodes of rape and sentenced him to reclusion perpetua, ordering him to pay civil indemnity and moral damages. The Court of Appeals affirmed the conviction with modification, adding an award for exemplary damages.
ISSUE
Whether the Court of Appeals correctly affirmed the conviction of accused-appellant Leonardo Castrodes for the crime of rape.
RULING
Yes, the Supreme Court affirmed the Decision of the Court of Appeals in toto. The Court held that: (1) rape can be committed even in broad daylight and in a place not secluded, as a perpetrator’s desire is not hindered by time or place; (2) the delay in reporting the incident does not undermine the victim’s credibility, as it is not uncommon for a young victim to conceal the assault due to fear and social stigma; (3) the absence of vaginal lacerations in the medical examination does not negate rape, as medical findings are dispensable in a rape prosecution; and (4) the defense of alibi must fail as the accused failed to prove the physical impossibility of his presence at the crime scene, given that the farm where he claimed to be was only a twenty-minute walk away. The conviction and the awarded damages, including civil indemnity, moral damages, exemplary damages, and legal interest, were upheld.