GR L 45087; (October, 1984) (Digest)
G.R. No. L-45087 October 23, 1984
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. PROCESO ABALLE Y QUINDALA alias “SISOY”, defendant-appellant.
FACTS
The defendant-appellant, Proceso Aballe, was convicted of rape by the trial court and sentenced to reclusion perpetua. The complainant was Josephine Angel, an eleven-year-old girl who was mentally retarded. During her testimony, she was extremely reluctant, crying and whispering, requiring the judge to descend from the bench to question her. She testified that Aballe, a neighbor nicknamed “Sisoy,” brought her to a dark area called the “reclamation,” laid her down, undressed her, and inserted his penis into her, causing her pain and bleeding. Her testimony was corroborated by her mother, relatives, and medical experts. A medical certificate indicated fresh lacerations on her hymen.
ISSUE
Whether the constitutional presumption of innocence of the accused was overcome by proof beyond reasonable doubt, justifying his conviction for rape.
RULING
Yes, the conviction is affirmed. The Supreme Court emphasized the duty for extreme care in reviewing rape convictions, especially when the complainant is a child below twelve and mentally retarded, and the penalty is severe. The Court meticulously scrutinized the records and found the trial court’s exhaustive decision persuasive. The complainant’s testimony, though given with difficulty, was credible and consistent on material points: the accused brought her to an isolated place, undressed her, and performed the carnal act. Her mental condition did not detract from her credibility; instead, it explained her demeanor and simple answers. Her testimony was substantially corroborated by medical evidence of fresh hymenal lacerations, supporting a finding of penetration, which need not be complete for rape. The totality of the prosecution’s evidence, including witness testimonies, sufficiently established all elements of statutory rape, given the victim’s age. The constitutional presumption of innocence was therefore rightly deemed overcome by proof beyond reasonable doubt. The penalty was correctly imposed as reclusion perpetua.