G.R. No. L-68574 July 7, 1986
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DOROTEO BAAO, accused-appellant.

FACTS

The accused-appellant, Doroteo Baao, was convicted by the trial court of two counts of rape against thirteen-year-old Rowena Federio. The prosecution alleged that Baao raped Federio five times between December 1982 and February 1983. The complainant, described by the trial judge as an unschooled, timid barrio lass with low mentality, reported the incidents to her mother in March 1983. Medical examination confirmed defloration and physical findings compatible with recent sexual intercourse. The defense presented alibi and denial, claiming the charges were fabricated as revenge because Baao had once scolded Federio for stealing from his store. Baao asserted he was in Baclaran during the alleged December incidents, corroborated only by his daughter.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused-appellant for the crimes of rape beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction for two counts of rape but acquitted the accused-appellant for the three other alleged rapes due to insufficient proof. The Court found the testimony of the complainant credible, emphasizing her naivete and limited intelligence, which made it improbable she could fabricate a detailed tale of multiple rape. The medical evidence substantiated her claim of sexual intercourse. The Court rejected the defense of alibi as inherently weak, noting it was corroborated only by a biased witness (his daughter) and failed to prove the physical impossibility of Baao’s presence at the crime scene. The motive of revenge alleged by the defense was deemed insufficient to overturn the positive identification and credible narrative of the victim. The penalty of reclusion perpetua for each of the two convicted counts was sustained, along with an award of moral damages. The Court highlighted the particular reprehensibility of the crime given the victim’s youth and vulnerability.