GR 165223; (January, 2016) (Digest)
March 12, 2026GR L 4037; (November, 1951) (Digest)
March 12, 2026G.R. No. 98704 September 8, 1994
People of the Philippines, plaintiff-appellee, vs. Arvel Saballe, alias Bebot alias Betrok, accused-appellant.
FACTS
Accused-appellant Arvel Saballe was charged with the statutory rape of six-year-old Maricel Rendora on March 1, 1989, in Tolosa, Leyte. The prosecution evidence established that the victim’s mother, Imelda Rendora, left her three children, including Maricel, alone in their house. While she was outside, appellant entered, enticed Maricel to play, forced himself on top of her, and inserted his penis into her vagina, causing pain, bleeding, and a fresh hymenal laceration. Upon returning, Imelda found Maricel crying and bleeding. They proceeded to the Leyte Provincial Hospital, where Dr. Lydia B. Hayabo medically confirmed the fresh laceration and penetration. Maricel identified appellant as the perpetrator. Appellant denied the charge, claiming alibi and alleging the complaint was fabricated due to a past land dispute between their families.
ISSUE
Whether the prosecution proved the guilt of accused-appellant beyond reasonable doubt.
RULING
Yes. The Supreme Court affirmed the trial court’s decision finding appellant guilty of statutory rape. The medical certificate and testimony of Dr. Hayabo conclusively established sexual assault. The victim’s categorical, straightforward, and unshaken identification of appellant as her assailant was given full faith and credit. Appellant’s defense of denial and alibi was unavailing; his claim of being at a ricefield 180 meters away did not make it physically impossible for him to be at the crime scene. The Court rejected the motive of revenge as implausible, noting it was inconceivable for a mother to subject her young daughter to the rigors of a rape trial for such a purpose. The penalty of reclusion perpetua and an indemnity of P20,000 were upheld.
