G.R. No. 76468 August 20, 1990
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ANTONIO DOLORES, accused-appellant.

FACTS

The case involves the statutory rape of Ana Rowena Prior, who was twelve years old at the time of the incident on November 1, 1979. Ana and her family lived in the same tenement building as the accused, Antonio Dolores, who operated a store on the ground floor. Ana testified that on said date, she was lured to Dolores’s store under the pretense of receiving a birthday gift. Once inside, Dolores pushed her into a mezzanine area, forcibly undressed her, and proceeded to have carnal knowledge. Ana resisted and felt pain, and the act was interrupted when a female voice called for Dolores. Out of fear due to threats from the accused, Ana did not report the incident until five months later, following a subsequent inappropriate touching incident at the store which led to a confrontation and her mother reporting the crimes to the police.
A medical examination by the NBI conducted on May 13, 1980, found Ana’s hymen intact with a small orifice, a finding which the defense argued precluded complete penetration. However, the prosecution presented a contrary medico-legal certificate from the PC Crime Laboratory, issued later, indicating non-virginity. The trial court convicted Antonio Dolores of rape, giving greater weight to the testimonial evidence of the victim and the subsequent PC Crime Laboratory report. The accused appealed, contending that the contradictory medical reports created reasonable doubt.

ISSUE

Whether the contradictory medical reports create reasonable doubt sufficient to overturn the conviction for rape based on the victim’s testimony.

RULING

The Supreme Court affirmed the conviction. The legal logic centers on the principle that a conviction for rape can rest solely on the credible testimony of the victim, especially a minor, and that medical evidence is merely corroborative. The Court clarified that the NBI finding of an intact hymen did not negate the commission of rape, as it only precluded complete penetration. Ana’s own testimony detailed only a slight penetration, which was interrupted. In rape, the crime is consummated by the slightest penetration of the female labia; neither complete penetration nor the rupture of the hymen is required. The contradictory medical reports do not cancel each other out, as the victim’s clear and consistent narrative, coupled with the PC Crime Laboratory’s findings presented at trial, sufficiently established guilt beyond reasonable doubt. The case involved statutory rape under Article 335 of the Revised Penal Code, where the victim’s age below twelve is the central element, rendering proof of force or intimidation unnecessary. The State’s role as parens patriae mandates the utmost protection of minors, justifying the rigorous application of the penal law in such cases.