G.R. No. 80532 November 8, 1993
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CRISTITUTO ALEGADO Y BULLO @ “TOTOY”, accused-appellant.

FACTS

On November 15, 1970, at around noon, sixteen-year-old complainant Alejandra Evangelista was walking home in Mangatarem, Pangasinan. She noticed accused-appellant Cristituto Alegado and another man following her. Appellant eventually overtook her, held her, thrust a knife at her neck, and dragged her to a forested area about fifteen meters from the road. There, he pushed her to the ground, removed her trousers and underwear, and despite her pleas and resistance, slapped her, held her shoulders, and succeeded in inserting his penis into her vagina. After satisfying his desire, the complainant managed to free herself, ran to the road shouting for help, and was assisted by an old man, Aldo de la Cruz. The incident was reported, and a medico-legal examination conducted on the same day revealed lacerations on her hymen and other injuries. The complaint for rape was filed on November 17, 1970, but the appellant evaded arrest for fifteen years. An Information was finally filed on July 2, 1985, after his arrest. The trial court convicted him of rape and sentenced him to reclusion perpetua and moral damages. Appellant appealed, contending that inconsistencies in the complainant’s testimony and sworn statements created reasonable doubt and that the prosecution failed to prove his guilt beyond reasonable doubt.

ISSUE

Whether the trial court erred in convicting the accused-appellant of rape despite the alleged inconsistencies in the complainant’s testimony and sworn statements, and the alleged failure of the prosecution to prove his guilt beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The alleged inconsistencies between the complainant’s court testimony and her prior sworn statements were deemed inconsequential. The Court held that sworn statements are generally considered inferior to testimony given in open court, as they are often incomplete. Furthermore, the appellant failed to properly impeach the witness during trial by confronting her with these statements, as required by the rules on evidence. The Court also found that the complainant’s credible and categorical testimony, corroborated by the medical findings of hymenal lacerations, sufficiently established the commission of rape by force and intimidation. The appellant’s flight and evasion of arrest for fifteen years were considered indications of guilt. The defense’s arguments regarding the complainant’s alleged pregnancy and menstrual flow at the time of the incident were dismissed as irrelevant to the essential elements of rape. The penalty of reclusion perpetua and the award of moral damages were upheld.