G.R. Nos. 80437-38 July 11, 1996
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROBERTO B. ABORDO, accused-appellant.

FACTS

Roberto Abordo, a houseboy employed for less than a week, was charged with the rape and attempted rape of his employer’s 10-year-old daughter, Arlene Tan. The first incident allegedly occurred on August 7, 1982, at night, where Abordo entered Arlene’s room, undressed her, and had carnal knowledge while threatening her and covering her mouth. Her four-year-old brother, Aris, was present but did not intervene. The second incident, charged as attempted rape, happened on August 15, 1982, in the morning. Abordo entered the room while Arlene and Aris were playing, undressed her, and attempted to insert his penis from behind. Arlene resisted and called for help, prompting Aris to hit Abordo with a piece of wood, causing him to flee. The crimes were reported to their father, Antonio Tan, leading to Abordo’s arrest.
The prosecution presented the testimonies of the child victim and her young brother. A medico-legal examination confirmed the presence of contusions and healed lacerations consistent with sexual assault. The defense consisted of denial and alibi, claiming Abordo was elsewhere during the incidents. The trial court convicted Abordo of rape and attempted rape, sentencing him to reclusion perpetua and an indeterminate prison term, respectively, and ordering him to pay indemnities.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused beyond reasonable doubt for the crimes of rape and attempted rape.

RULING

The Supreme Court affirmed the conviction. The Court emphasized that the testimonies of young rape victims are given full weight and credit. Arlene’s candid and consistent narration of the traumatic events, delivered without any apparent motive to fabricate, was deemed credible. The Court held that no young girl would willingly undergo the ordeal of a public trial and physical examination unless motivated by a genuine desire for justice. Her testimony on the consummated rape was credible despite the absence of fresh lacerations, as the medico-legal findings of healed lacerations were consistent with the August 7 incident. For the attempted rape, her account was strongly corroborated by her brother Aris, whose testimony, though from a child witness, displayed natural candor and lack of prevarication. The defense of denial and alibi, unsubstantiated by clear and convincing evidence, could not prevail over the positive identification by the victims. The Court modified the decision by increasing the civil indemnity to P50,000 for rape and P10,000 for attempted rape, aligning with prevailing jurisprudence on moral damages for such crimes.