G.R. No. 97222 November 28, 1995
People of the Philippines, plaintiff-appellee, vs. Vicente Jimenez y Luna, accused-appellant.

FACTS

The case involves the rape of Tisa Imperial, a 14-year-old girl, by her uncle, accused-appellant Vicente Jimenez y Luna, in November 1986 in Zamboanga City. Tisa was living with her aunt as her mother worked abroad. One evening, appellant called her, dragged her to a nearby comfort room, threatened to kill her if she shouted, gagged her mouth with a rag, tied her hands and feet with her torn shorts, and forcibly had carnal knowledge of her. After the act, he threatened her again and left. Tisa did not immediately report the incident due to fear and the absence of her mother. She finally disclosed the crime in July 1987 upon her mother’s return, leading to a medical examination that confirmed healed hymenal lacerations and a five-month pregnancy.
Appellant was convicted of rape by the Regional Trial Court and sentenced to reclusion perpetua. On appeal, he argued that the prosecution failed to prove his guilt beyond reasonable doubt, citing alleged inconsistencies in Tisa’s testimony, her failure to immediately resist and report the crime, and suggesting the complaint was politically motivated due to a barangay election dispute.

ISSUE

Whether the prosecution proved the guilt of the accused-appellant for the crime of rape beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The Court held that the alleged inconsistencies in the victim’s testimony regarding minor details, such as whether she was standing or lying down when tied, did not undermine her credibility but instead indicated her unrehearsed narration. The Court emphasized that in rape cases, the testimony of the victim, if credible, is sufficient to sustain a conviction.
The delay in reporting the crime was satisfactorily explained by the victim’s young age, fear for her life due to appellant’s threats, and the absence of her mother for moral support. The Court found this delay reasonable and not indicative of a fabricated charge. The defense’s theory of political motivation was rejected as absurd, noting no mother would subject her daughter to the stigma of a false rape case over a minor electoral contest.
The medical findings of healed hymenal lacerations and pregnancy corroborated the fact of sexual intercourse. The defense’s attempt to impugn the victim’s moral character was dismissed, given her tender age. The Court found the prosecution’s evidence, comprising the victim’s clear and credible testimony and medical proof, to have established appellant’s guilt beyond reasonable doubt, thereby upholding the trial court’s judgment.