G.R. No. 84729, July 30, 1990
People of the Philippines vs. Wilfredo Albarillo

FACTS

The prosecution’s evidence established that on January 14, 1986, in Sitio Ibuye, San Teodoro, Oriental Mindoro, complainant Melinda Cuaresma, then 15 years old, was gathering fern tops when she was accosted by appellant Wilfredo Albarillo. After a brief exchange, Albarillo forcibly embraced her, threatened to kill her if she shouted, and despite her resistance of kicking and boxing, succeeded in having carnal knowledge with her. The victim immediately ran home, crying, and reported the rape to her mother. They promptly reported the incident to barangay officials and the police. A medical examination conducted the following day revealed fresh lacerations on her hymen and contusions on her body, corroborating her account of a violent assault.
The defense interposed an alibi, claiming appellant was at his construction job in Barangay Villaflor at the time of the incident. He asserted he only learned of the charge two days later. Appellant also suggested that the complaint was fabricated due to a long-standing feud between their families, implicating motives related to trespassing on their land and an insurance premium dispute.

ISSUE

The ultimate issue is whether the prosecution proved appellant’s guilt for the crime of rape beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The Court emphasized that in rape cases, where the act is typically unwitnessed, the trial court’s assessment of witness credibility is accorded great respect, as it observed the witnesses’ demeanor firsthand. The testimony of the young, unsophisticated complainant was found to be credible, straightforward, and consistent. The Court held it was highly improbable for a young barrio lass to fabricate a story of defloration, undergo a medical examination, and endure a public trial unless motivated by a truthful desire for justice.
The medical certificate, showing fresh hymenal lacerations and hematomas, provided strong physical corroboration of forcible intercourse and resistance. The defense of alibi was rejected as inherently weak. The Court noted that the distance between the crime scene and appellant’s alleged workplace was not considerable and could be traversed, making it physically possible for him to have committed the crime and then proceeded to work. Furthermore, the purported motives for fabrication—family grudges over land and insurance—were deemed insufficient to compel a mother to subject her daughter to the shame and ordeal of a rape prosecution. Appellant’s guilt was thus established beyond reasonable doubt. The penalty of reclusion perpetua was affirmed, but the indemnity was increased to Thirty Thousand Pesos (P30,000.00).