G.R. No. L-51034. May 29, 1987.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MARCELO VALDEZ y MANZON, accused-appellant.

FACTS

The accused-appellant, Marcelo Valdez, was convicted of rape by the Court of First Instance of Pangasinan and sentenced to reclusion perpetua. The prosecution evidence established that on December 21, 1977, Valdez, then 20 years old and a frequent boarder with the Baliton family, entered their home in San Quintin, Pangasinan, while the 13-year-old complainant, Lolita Baliton, was with her 12-year-old friend. Brandishing a balisong, he threatened to kill them and their families if they screamed. He then forced Lolita down, lowered her underwear, and succeeded in having carnal knowledge against her will. The act was repeated in January 1978 under similar threats. Lolita revealed the assaults to her mother in February 1978, leading to a medical examination which revealed old lacerations consistent with sexual intercourse, and the subsequent filing of the criminal case.

ISSUE

The core issue is whether the trial court erred in convicting the accused based on the credibility of the complainant’s testimony, despite the defense’s claims of a romantic relationship, inherent improbabilities in her account, and a delay in reporting the crime.

RULING

The Supreme Court affirmed the conviction, upholding the trial court’s assessment of witness credibility. The Court found the testimony of the young complainant, corroborated by her friend’s account and the medical findings, to be credible and convincing. The minor inconsistencies noted were deemed natural for a young, unexposed barrio lass undergoing the stress of a public trial. The Court rejected the defense of a sweetheart theory as implausible. The alleged token of a ring was proven too small for the complainant, and no other substantial evidence of a relationship was presented. The appellant’s offer of marriage during the barangay investigation was construed not as proof of affection but as an implied admission of guilt. The delay in reporting was reasonably explained by the appellant’s continuing threats of death, which initially silenced the victims. The trial court’s observation of the appellant’s nervous, hesitant, and unreliable demeanor on the witness stand further undermined his defense. The narrative he presented—that the 13-year-old complainant openly solicited sex—was found to be a fabrication contrary to the moral setting of barrio life and the complainant’s tender age. Consequently, the prosecution successfully proved the appellant’s guilt beyond reasonable doubt. The appealed judgment was affirmed with the modification of increasing the civil indemnity to P20,000.00.