Facts:

In the last week of September 1988, Charina Alpuerto, a 14-year-old girl, went to the mountainside to retrieve her family's cow. While she was tethering the cow to a coconut tree, Mario Caballero, a 53-year-old fisherman, approached her from behind, embraced her, and covered her eyes with his shirt. He then tied her hands behind her back, pushed her to the ground, undressed her, and raped her. After the assault, Caballero threatened Charina with a knife, warning her not to tell anyone about the incident. Out of fear for her life, Charina did not disclose the rape to her parents.

In February 1989, Charina's mother, Pelagia Alpuerto, discovered that Charina was pregnant. Charina later gave birth in July 1989. During the trial, Caballero denied the allegations, claiming that he and Charina were lovers and that their sexual encounters were consensual. He asserted that Charina had professed her love for him and frequently visited him to borrow money. He contended that their relationship was ongoing and that Charina had informed him of her pregnancy, to which he promised support.

Caballero was charged with rape, pleaded not guilty, and was subsequently convicted by the Regional Trial Court, which sentenced him to reclusion perpetua and ordered him to pay Charina P30,000 in indemnity.

Legal Issues:

  1. Whether the trial court erred in giving credence to Charina Alpuerto's testimony, which the accused claimed was inconsistent and improbable.
  2. Whether the evidence presented by the prosecution was sufficient to overcome the presumption of innocence and establish Caballero's guilt beyond a reasonable doubt.

Arguments:

For the Accused-Appellant (Mario Caballero):

  • The testimony of Charina was inconsistent and implausible, particularly her failure to shout for help or escape despite being close to her home.
  • Charina did not sustain any injuries that would be expected from a violent struggle, which undermined her credibility.
  • The timeline of Charina's pregnancy was inconsistent with the alleged date of the rape, suggesting that the rape could not have occurred as claimed.
  • Caballero maintained that their sexual encounters were consensual and that Charina was his lover, which he argued was corroborated by her actions.

For the Plaintiff-Appellee (People of the Philippines):

  • Charina's testimony was credible and consistent, detailing the assault and the threats made by Caballero that prevented her from reporting the incident.
  • The absence of physical injuries was explained by the circumstances of the assault, including the use of threats and the victim's fear.
  • The timeline of the pregnancy was medically plausible, as the duration of pregnancy can vary significantly.
  • The trial court's assessment of Charina's credibility was supported by her straightforward manner of testimony, which did not exhibit signs of fabrication.

Court's Decision and Legal Reasoning:

The court affirmed the trial court's decision, emphasizing that the credibility of witnesses is primarily within the purview of the trial court. The court found that Charina's testimony was credible and consistent, despite the accused's claims of inconsistencies. The court noted that Charina's failure to report the incident immediately was understandable given the threats made by Caballero, which were corroborated by her testimony.

The court also addressed the timeline of Charina's pregnancy, stating that the medical variability in pregnancy duration could account for the timing of her delivery. The court rejected the "sweetheart theory" presented by Caballero, finding it to be self-serving and uncorroborated.

The court concluded that the trial court's findings were supported by the evidence and that Caballero's guilt was established beyond a reasonable doubt. The indemnity amount was increased from P30,000 to P50,000 in line with prevailing case law.

Significant Legal Principles or Doctrines Established:

  • The credibility of witnesses is primarily determined by the trial court, and its findings are given great weight on appeal unless there is a clear showing of error.
  • The victim's failure to report an assault immediately does not necessarily detract from their credibility, especially when threats of violence are involved.
  • The "sweetheart theory" is often viewed with skepticism in cases of alleged rape, particularly when unsupported by corroborating evidence.