G.R. No. 76531 November 15, 1989
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RICARDO SALITA y BETUS, defendant-appellant.

FACTS

On Good Friday, April 20, 1984, nine-year-old Sheila Linn Hayashi was left with her sister and a companion at their family resthouse in Valenzuela, Metro Manila, under the care of the caretaker, Linda Salita. The appellant, Ricardo “Carding” Salita, is Linda’s brother. That afternoon, Carding approached Sheila on the veranda, cuddled her, kissed her, and inserted a finger into her vagina. The following day, Holy Saturday, Carding entered the room where Sheila was reading, closed the door and windows, and after sitting beside her, pulled down her pants and his own. He placed her on top of his thighs, inserted his penis into her vagina, and moved her up and down. Sheila cried in pain. Afterward, Carding threatened to kill her and her mother if she told anyone. Sheila experienced pain and difficulty urinating, and blood stains were later found on her pants.
Upon returning to Manila, Sheila and her sister reported the incident to their mother, Soledad Tante Linn Hayashi. Soledad observed blood and pus in Sheila’s vagina and immediately had her medically examined and investigated. A criminal complaint for rape was subsequently filed by Soledad, as the victim’s mother, in the Regional Trial Court of Valenzuela. After trial, the court found Salita guilty of rape and sentenced him to reclusion perpetua, with damages. Salita appealed, challenging the credibility of the prosecution witnesses and the sufficiency of the evidence.

ISSUE

Whether the trial court erred in convicting the appellant of rape based on the credibility of the prosecution’s evidence.

RULING

The Supreme Court affirmed the conviction. The Court held that the complaint was properly filed by the victim’s mother, Soledad, pursuant to Section 5, Rule 110 of the Rules of Court, which allows parents to file a complaint when the offended party is a minor. The appellant’s challenge to the mother’s capacity was unfounded, as her relationship was established through her testimony and the victim’s birth certificate, which the appellant himself acknowledged.
On the main issue of credibility, the Court found the testimony of the child victim, Sheila, to be clear, spontaneous, and deserving of full credence. It was a candid account of a young child whose chastity was violated. Her testimony was corroborated by her sister, Jenny, who witnessed Carding kissing and embracing Sheila through a window, and by their mother, who observed the physical injuries and promptly sought medical examination. The Court rejected the appellant’s argument that the act was physically impossible due to their height difference, noting that the specific position described—with the victim placed on top of the appellant’s thighs—made consummation feasible regardless of stature.
The defense of alibi was deemed unavailing against the positive identification by the prosecution witnesses. The appellant’s claim that he was elsewhere dismantling sound equipment did not make it physically impossible for him to have committed the crime at the resthouse. The trial court’s assessment of witness credibility is accorded great weight, and the Supreme Court found no reason to overturn its findings. The evidence conclusively established the appellant’s guilt beyond reasonable doubt for the heinous crime of rape against a minor. The appealed judgment was affirmed in toto.