G.R. No. 8829 May 31, 1994
People of the Philippines, plaintiff-appellee, vs. Guillermo Casipit y Radam, accused-appellant.

FACTS

The victim, Myra Reynaldo, was a 14-year-old sixth grader, and the accused-appellant, Guillermo Casipit, was 22. They were neighbors in Victoria, Alaminos, Pangasinan. On September 19, 1986, Myra’s father entrusted her to appellant’s parents before leaving for Manila. Appellant invited Myra to go to the town proper to buy rice and bananas, but then suggested going to Dagupan City for cheaper prices, to which she agreed. In Dagupan, they watched a movie until 6:00 p.m., then returned to Alaminos by 8:00 p.m. After dinner, they proceeded home to Barangay Victoria. Due to heavy rain, they took shelter in a hut in an open field in Barangay Talbang. Inside, appellant told Myra to lie down with him, then went near her, removed her panties, poked a knife at her neck, and warned her not to shout. She resisted and kicked him twice, but he tied her hands behind her nape, opened her legs, went on top of her, and succeeded in having sexual intercourse with her. She felt pain and could not sleep. The next morning, they proceeded home. Upon arrival, her cousin-in-law observed she was walking abnormally. Her aunt, Nenita Rabadon, questioned her, and she narrated the incident. They reported it to the barangay captain. The victim was examined by her sister-in-law and the barangay captain’s wife, who found her private part reddish and her panties stained with blood. The following afternoon, Myra reported the rape to the police and was medically examined by Dr. Fideliz Ochave, who found a first-degree fresh healing laceration at the perineum and hymen but no external physical injuries; laboratory results were negative for spermatozoa. On September 26, 1986, Myra gave her statement to the police and filed a criminal complaint. Appellant claimed they were sweethearts and that the sexual intercourse was consensual, alleging that during the movie, they kissed and talked about their love, and that in the hut, she consented to the act. He contended the victim was induced by her aunt to file the case.

ISSUE

Whether the trial court erred in finding accused-appellant Guillermo Casipit y Radam guilty of rape beyond reasonable doubt.

RULING

The Supreme Court AFFIRMED the trial court’s decision finding appellant guilty of rape, with the modification that the indemnity to the victim is increased to P50,000.00. The Court held that the trial court’s factual findings, including its credence to the testimony of the victim that appellant used a knife and force to sexually abuse her despite her resistance, are entitled to the highest respect. The absence of external injuries does not negate rape, as proof of injuries is not an essential element of the crime; the force or intimidation used is relative and viewed in light of the victim’s perception. The fact that the victim went to a movie with appellant does not indicate consent to sexual intercourse, especially given her young age and their familial relation. Appellant’s defense of a sweetheart relationship was rejected, as the victim’s immediate reporting of the assault and submission to medical examination bolstered her credibility and negated consent. The Court emphasized the State’s obligation to protect minors, lending credence to the testimonies of young victims.