G.R. No. L-72573 August 31, 1987
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RENATO ALFONSO, defendant-appellant.

FACTS

The 13-year-old complainant, Laila Indita, traveled alone from Isabela to Manila. Upon arriving at a bus terminal in Quezon City in the early morning of April 3, 1982, she was approached by appellant Renato Alfonso, a relative and neighbor from her hometown. He offered to accompany her to her uncle’s house. Trusting him, she accepted. Appellant led her to a dark area within the terminal compound, pushed her down, and despite her resistance and shouts, forcibly had carnal knowledge of her. He threatened her with a knife when she cried for help. After the act, appellant left. Laila proceeded to her uncle’s house but only revealed the rape to her mother three days later, after which a medical examination and a complaint were filed.
The defense interposed denial and alibi. Appellant claimed he was at the Philippine Heart Center attending to his hospitalized wife during the alleged incident. A neighbor corroborated his presence at the hospital. He suggested the charge was motivated by his refusal to lend money to Laila’s uncle, who then threatened to harass him.

ISSUE

Whether the guilt of the accused for the crime of rape was proven beyond reasonable doubt.

RULING

Yes, the conviction is affirmed. The Supreme Court found the testimony of the young victim to be clear, convincing, and credible. The Court emphasized that in rape cases, the complainant’s testimony, if credible, is sufficient to sustain a conviction. The Court rejected the defense of alibi as weak and inherently unreliable, especially since it was not physically impossible for the appellant to have been at the crime scene. The positive identification by the victim, who knew the appellant well, prevails over alibi. The Court also addressed several arguments raised to impugn the prosecution’s case. The delay in reporting the incident was satisfactorily explained by the victim’s fear and tender age. The absence of spermatozoa in the medical report and the non-presentation of the victim’s clothing do not negate rape, as medical findings are merely corroborative and not indispensable. The alleged motive of revenge was deemed insufficient to overturn the positive and categorical testimony of the victim. The trial court’s assessment of credibility is accorded great respect. All elements of rape—carnal knowledge through force or intimidation—were established beyond reasonable doubt.