G.R. No. 68422 , December 29, 1989
People of the Philippines, plaintiff-appellee, vs. Restituto Bravo y Bajaro, accused-appellant.

FACTS

The prosecution’s evidence established that on May 30, 1982, in Legaspi City, nine-year-old Meriam Balomino was gathering firewood when accused-appellant Restituto Bravo, a 67-year-old neighbor, chased her. He overtook her, gagged her mouth with a handkerchief, threatened her with a knife, and forcibly had carnal knowledge of her. Meriam felt pain and bled from her private parts. She immediately reported the rape to her mother, Rosita Balomino, who noticed blood on her daughter’s skirt. They proceeded to the police and then to the Albay Provincial Hospital for examination.
Dr. Eduardo Martinez conducted the medico-legal examination and found Meriam’s vulva soaked with fresh blood, with a moderately bleeding laceration at the hymen requiring stitches. The defense presented an entirely different version, claiming Meriam was known to be mentally deficient and had accidentally fallen from a kasuy tree, impaling her private parts on a protruding stick. To support an alibi, defense witnesses testified that Restituto was at his daughter’s house during the incident, unloading coconut midribs.

ISSUE

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

RULING

Yes. The Supreme Court affirmed the conviction. The trial court’s assessment of the credibility of witnesses is accorded great respect, and it correctly found the prosecution’s evidence, particularly the consistent and credible testimony of the young victim, to be more convincing. The medical findings of Dr. Martinez corroborated Meriam’s account of a violent sexual assault. The Court found the defense’s alternative theory—that the injuries resulted from an accidental fall—to be inherently implausible and unsupported by credible evidence. The testimony of defense witness Petronilo Prinsipe, who claimed to have witnessed the fall from a significant distance through obstructing foliage, was deemed improbable and failed to cast reasonable doubt on the established facts of the case. The defense of alibi likewise crumbled, as it was not physically impossible for the accused to have been at the crime scene. Consequently, all elements of rape under Article 335 of the Revised Penal Code, given the victim’s age of nine, were sufficiently proven. The Court modified the judgment by increasing the civil indemnity awarded to the victim from P12,000.00 to P30,000.00, in line with prevailing jurisprudence, and affirmed the penalty of reclusion perpetua.