Facts:

The case involves Proceso Aballe y Quindala, also known as "Sisoy," who was accused of raping an eleven-year-old girl named Josephine Angel, nicknamed "Joy." The incident occurred on January 25, 1976, in Cebu City, during a coronation dance attended by Joy's mother, Rosita Angel. After the dance, Rosita discovered that Joy was missing and learned from friends that she had been taken to a nearby reclamation area by Proceso Aballe, a close neighbor. Rosita, along with her sister and some neighbors, searched for Joy and eventually found her at the reclamation area, where she was seen pulling up her shorts. Proceso Aballe was spotted nearby and fled upon seeing the group.

Joy was taken home, where her aunt, Gala Pestano, questioned her about the incident. Joy disclosed that Sisoy had bitten her and removed her panty. A bloodstained panty was later found by Gala. Joy was taken to the Cebu City Hospital for examination, where a medical certificate indicate...

Facts:

1. Complainant's Background:

   • Josephine Angel, nicknamed "Joy," was an 11-year-old mentally retarded girl. She was easily influenced by her friends and had difficulty communicating.
   • At the time of the incident, she was in Grade III but had stopped schooling due to her mental condition.

2. The Incident:

   • On January 25, 1976, a coronation dance was held in Villa Gonzalo I, Cebu City. Joy’s mother, Rosita Angel, attended the event with her sister, Gala Pestano, and niece, Zenaida Tablo.
   • Around 10:00 PM, Rosita returned home and discovered Joy was missing. She was informed by neighbors that Joy had been taken to the reclamation area by Proceso Aballe, alias "Sisoy," a close neighbor.
   • Zenaida Tablo and others searched for Joy and found her in the reclamation area, pulling up her shorts. They saw Sisoy running away.
   • Joy was brought home, where her aunt Gala examined her and found her yellow panty bloodstained.

3. Medical Examination:

   • Joy was taken to the Cebu City Hospital, where Dr. Caridad Mancao conducted a physical examination. The findings included fresh lacerations of the hymen and a bloodstained panty.

4. Testimonies:

   • Joy testified that Sisoy took her to the reclamation area, undressed her, and inserted his penis into her. She also stated that he bit her lips and ran away when he saw people approaching.
   • Other witnesses, including Joy’s mother, aunt, and cousin, corroborated her account.

5. Defense’s Version:

   • Proceso Aballe denied the allegations, claiming he was drunk and had gone to the reclamation area to get fresh air. He alleged that the case was filed because the complainant’s family believed his aunt, who owned taxis, would settle the case for him.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Credibility of the Complainant’s Testimony:

   • Despite Joy’s mental retardation and difficulty in communicating, her testimony was consistent and corroborated by other witnesses and medical evidence. The Court found her account credible, especially given her young age and mental condition.

2. Medical Evidence:

   • The medical findings, including fresh lacerations of the hymen and the bloodstained panty, supported the claim of sexual assault.

3. Defense of Alibi and Denial:

   • The defense of alibi was weak and unsupported by credible evidence. The accused’s claim that he was elsewhere at the time of the incident was contradicted by the testimony of Zenaida Tablo, who saw him fleeing the scene.

4. Statutory Rape:

   • Since Joy was below 12 years old at the time of the incident, the crime qualified as statutory rape, which does not require proof of force or intimidation.

5. Presumption of Innocence Overcome:

   • The prosecution successfully overcame the constitutional presumption of innocence by presenting clear, positive, and satisfactory evidence of the accused’s guilt.