Facts:

Roberto Abordo was employed as a houseboy by Antonio Tan, who lived in Quezon City with his children, including his 10-year-old daughter, Arlene Tan. On August 7, 1982, at approximately 10:30 PM, Arlene was awakened to find Abordo on top of her, having undressed her. He kissed her, pinned her down, and forcibly had sexual intercourse with her, threatening her with harm if she screamed. Arlene's four-year-old brother, Aris, was nearby and witnessed the incident but was too young to intervene effectively. The following day, Abordo warned Arlene not to disclose the incident.

On August 15, 1982, while playing with Aris, Abordo again entered their room, undressed Arlene, and attempted to rape her. Aris witnessed this as well and intervened by hitting Abordo with a piece of wood, causing him to flee. Arlene later confided in her cousin about the incidents, leading to a confrontation with Abordo and ultimately to the filing of complaints against him.

Medical examination of Arlene revealed signs of sexual abuse, including lacerations consistent with forced intercourse. Abordo denied the allegations, claiming he was not present during the incidents and asserting that the family members were in the house at the time, which would have made it impossible for him to commit the crimes.

Legal Issues:

  1. Whether the trial court erred in believing the testimonies of the victim and her brother, given the alleged improbability of the crimes occurring in the presence of other household members.
  2. Whether the absence of physical evidence of rape undermined the prosecution's case.
  3. Whether the conviction for attempted rape was valid based on the testimony of the victim alone.

Arguments:

For the Prosecution:

  • The prosecution argued that the testimonies of Arlene and Aris were credible and consistent, despite the presence of other family members in the house. They contended that fear of discovery does not preclude the commission of rape.
  • The medical findings corroborated Arlene's account, indicating that she had been sexually abused.
  • The prosecution maintained that the testimony of a minor victim is often sufficient for conviction, especially when there is no motive to fabricate the story.

For the Defense:

  • Abordo's defense relied on denial, asserting that he could not have committed the acts due to the presence of the victim's father and brother in the house.
  • The defense argued that the lack of immediate physical evidence, such as bleeding or severe pain, suggested that the alleged rape did not occur.
  • They contended that the testimony of the victim was uncorroborated and therefore insufficient for a conviction.

Court's Decision and Legal Reasoning:

The court affirmed the trial court's decision, finding that the testimonies of Arlene and Aris were credible and compelling. The court noted that the fear of discovery does not negate the possibility of rape occurring, especially in a domestic setting where the perpetrator may believe they can act without being caught. The court emphasized that the absence of fresh physical evidence does not invalidate the victim's testimony, particularly in statutory rape cases where the age of the victim is a critical factor.

The court also highlighted that the testimony of a minor victim, if credible, is sufficient for conviction, and corroboration is not always necessary. The medical examination findings supported the victim's account, indicating that she had been sexually abused. The court concluded that the evidence presented was sufficient to uphold the convictions for both rape and attempted rape.

Significant Legal Principles Established:

  • The court reaffirmed that the testimony of a minor victim is often sufficient for a conviction in rape cases, especially when there is no apparent motive to lie.
  • The ruling clarified that the absence of immediate physical evidence does not negate the occurrence of rape, particularly in cases involving minors.
  • The court reiterated that fear of discovery does not prevent the commission of rape, and such acts can occur even in the presence of others.