People v. Matias Graza y Fetil
REITERATIONFacts
The Antecedents: The case involves an alleged rape of a seven-year-old girl, Luz Cerilo, by the defendant-appellant, Matias Graza y Fetil, on October 22, 1984. The victim testified that the appellant offered her money, then pursued her, threatened her, and forcibly had sexual intercourse with her in a forested area. She lost consciousness during the assault and later experienced pain and fever. Her mother discovered injuries and a sticky substance on her daughter's clothing, leading to a medical examination that revealed swollen and painful labia and an obliterated hymen. The appellant claimed alibi, stating he was working in his rice field during the time of the incident. Procedural History: The Regional Trial Court (RTC) of Iriga, Branch 35, found the appellant guilty of rape and sentenced him to an indeterminate penalty of seventeen (17) years, four (4) months, and one (1) day to twenty (20) years of reclusion temporal. The RTC rejected the appellant's defense of alibi, noting that the path from the victim's school to her home passed by the rice field where the appellant claimed to be working. The appellant appealed this decision to the Court of Appeals, challenging the victim's testimony and the lack of physical evidence. The Court of Appeals affirmed the RTC's findings but modified the penalty to reclusion perpetua and increased the indemnity to P20,000.00. Due to the imposition of reclusion perpetua, the case was certified to the Supreme Court. The Petition: This case reached the Supreme Court via certification from the Court of Appeals, as mandated by Section 5, paragraph 2(D), Article VIII of the 1987 Constitution, for cases where the penalty imposed is reclusion perpetua or higher. The appellant's arguments before the Court of Appeals, which were considered in the certification, included claims that the victim's testimony was conflicting and unclear, that she did not immediately report the incident to her parents, that there was no physical evidence of injury, and that his alibi was supported by his wife. The Supreme Court, in its review, affirmed the Court of Appeals' decision, upholding the conviction and increasing the indemnity to P30,000.00, finding no reversible error.
Issue(s)
Whether the Court of Appeals erred in affirming the conviction of the accused for rape. Whether the testimony of the offended party, a seven-year-old child, was sufficient to support conviction in the absence of other corroborative evidence. Whether the accused's defense of alibi should have been accepted given witness testimony supporting that alibi. Whether the proper penalty is reclusion perpetua and whether the indemnity awarded should be modified.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals. The accused is sentenced to suffer the penalty of reclusion perpetua and to indemnify the victim in the amount of P30,000.00. No pronouncement as to costs.
Ratio Decidendi
On Whether the Court of Appeals erred in affirming the conviction of the accused for rape: The Court held that there was no reversible error in the Court of Appeals decision. The appellate court had reviewed the credibility of witnesses and the evidentiary record and found the testimony of the offended party credible and consistent in material particulars. The Supreme Court emphasized that in crimes against chastity the testimony of the offended party should not be received with precipitate incredulity, especially when the victim is a young child and there is no indication of motive to falsify. Applying People v. Felipe Marapao and Cesar Relivo (G.R. Nos. 68265-66), the Court noted that a child victim’s delay or failure to immediately report the incident does not automatically destroy credibility where fear or intimidation was evident. The Court therefore concluded that the conviction was properly affirmed on the factual findings of the lower courts. On Whether the testimony of the offended party was sufficient to support conviction: The Court reiterated that conviction for statutory rape under paragraph 3, Article 335, Revised Penal Code requires only one basic element: carnal knowledge of a female below twelve years of age. Citing People v. Alberto Barro, Jr. y Relon (G.R. No. 86385), the Court stated that sexual congress with a girl under twelve years is always rape and that force, intimidation or physical evidence of injury are immaterial to the element required by statute. The victim here positively identified the accused and there was medical evidence in the form of a medical certificate documenting swollen labia and an obliterated hymen, which corroborated the account of the victim. The Court further observed that the victim had no apparent motive to fabricate her testimony and that her fear of reprisals explained her initial silence. Considering the totality of evidence, the Court found the testimony of the offended party sufficient to support conviction. On the Defense of Alibi: The Court explained that for an alibi to succeed it must establish that it was physically impossible for the accused to have been at the scene of the crime at the time of its commission. The record showed that the accused claimed to be working in the ricefield during the relevant time, but the defense failed to present corroborating witnesses who could have confirmed the alibi, namely a helper who was mentioned in the trial. Applying People vs. Alvarez (G.R. No. 70446) and related authorities, the Court noted that an alibi that could have been corroborated but was not merits rejection. The Court further pointed to the geographic layout and testimony indicating the accused could have been at the scene, undermining the claim of physical impossibility. Consequently, the Court found no basis to accept the alibi defense. On Penalty and Indemnity: The Court found that the penalty of reclusion perpetua was proper given the nature of the offense and the victim’s age and circumstances. The Court increased the indemnity to P30,000.00 in line with prevailing jurisprudence, thereby modifying the amount previously awarded by the Court of Appeals. The Supreme Court thus affirmed both the conviction and the modified civil indemnity awarded to the victim.
Main Doctrine
Conviction for statutory rape under Article 335, par. 3, Revised Penal Code requires only carnal knowledge of a female under twelve years of age; the testimony of the offended party, particularly when the victim is a young child and credible, may suffice for conviction even without physical evidence; the defense of alibi requires a showing of physical impossibility and preferably corroboration.