G.R. No. 115983, April 12, 1996

Facts:

The case involves the accused-appellant, Clemente Ulpindo, who was charged with the crime of statutory rape against seven-year-old Regina Pelayo. The information filed on July 19, 1991, alleged that the crime occurred in the last week of December 1990 in Tagudin, Ilocos Sur. Regina testified that while she was sweeping the backyard one afternoon, Ulpindo approached her, pulled her into his kitchen, and allegedly had carnal knowledge of her for about five minutes despite her shouting and crying. He threatened her with death if she disclosed the incident to her mother.

Regina's mother, Resurreccion Pelayo, testified that Regina began complaining of pain in her crotch in early January 1991, leading to a medical examination where bruising and swelling were observed. A midwife, Jessimar Lascota, confirmed the presence of bruising and noted that Regina eventually disclosed that Ulpindo had raped her. Medical examinations revealed hymenal lacerations, but the attending physician, Dr. Eugene Dauz, stated that these could not definitively be attributed to rape, as they could also result from other factors, including physical trauma from a belt.

The defense presented evidence that Ulpindo was not present at the time of the alleged incident, asserting that Regina was injured while being whipped for stealing mangoes. The defense also challenged the medical findings, arguing that the injuries could have been caused by the whipping rather than rape.

Legal Issues:

  1. Whether the trial court erred in giving weight to the testimonies of the prosecution witnesses.
  2. Whether the trial court erred in finding the accused-appellant guilty beyond a reasonable doubt of the crime of rape.

Arguments:

Prosecution:

  • The prosecution argued that Regina's testimony, despite its inconsistencies, was credible and sufficient to establish that she was raped. They contended that the crime of statutory rape does not require proof of force or intimidation since the victim was under twelve years of age.
  • The prosecution emphasized that Regina's age and the trauma she experienced could explain any lapses in her testimony.

Defense:

  • The defense contended that Regina's testimony lacked critical details necessary to establish that rape occurred, such as being forced to lie down or having her clothes removed.
  • They argued that the medical evidence did not conclusively prove that Regina was raped, as the injuries could have resulted from the whipping incident.
  • The defense also pointed out that the timeline of events raised doubts about the occurrence of the alleged rape.

Court's Decision and Legal Reasoning:

The Regional Trial Court convicted Ulpindo, sentencing him to reclusion perpetua. However, upon appeal, the Supreme Court reversed the decision, acquitting Ulpindo based on reasonable doubt. The Court found that the prosecution failed to establish beyond a reasonable doubt that the crime of rape occurred.

The Court noted several inconsistencies in Regina's testimony, particularly regarding the timeline of events and the nature of the injuries. It highlighted that Regina could not remember the exact date of the alleged rape but recalled details about the whipping incident. The Court also pointed out that the medical evidence was inconclusive, as the hymenal lacerations could not be definitively attributed to rape.

The Court reiterated the principle that the prosecution bears the burden of proof and that evidence must be credible and convincing. It emphasized that while the testimony of a rape victim is crucial, it must not be inherently improbable or contradicted by other evidence.

Significant Legal Principles Established:

  • The case underscores the importance of corroborative evidence in rape cases, particularly when the victim is a minor.
  • It reaffirms that the prosecution must prove guilt beyond a reasonable doubt, and the burden of proof lies with the prosecution, not the defense.
  • The decision highlights the need for clear and consistent testimony in sexual assault cases, especially when medical evidence is inconclusive.