Case Digest (G.R. No. 134939)
Facts:
People of the Philippines v. Rodolfo Bato alias "Rudy Bato," G.R. No. 134939, February 16, 2000, Supreme Court First Division, Pardo, J., writing for the Court.The People (plaintiff-appellee) charged accused-appellant Rodolfo Bato with rape by Information filed February 21, 1995, alleging that on October 5, 1994, at about 3:00 p.m. in Brgy. Burgos, San Antonio, Zambales, the accused, by force and intimidation, had carnal knowledge of Delia Hernandez, a nine-year-old ward of the Shepherd of the Hills Compound. At arraignment on March 29, 1995, the accused pleaded not guilty and trial ensued before the Regional Trial Court (RTC), Branch 71, Iba, Zambales (Judge Romulo M. Estrada).
At trial the prosecution presented the victim Delia and fellow wards Maryjane Olympia and Jelyn, who testified that Delia was called by the accused, climbed a low fence to his lot, and was led to a grassy area where the accused undressed her and had sexual intercourse; Delia cried afterwards and showed soiled clothing and reddened genitalia. The victim was taken to the San Marcelino District Hospital where Dr. Ferdinand M. Llanes prepared a medico-legal certificate noting lacerations at the 3 and 6 o’clock positions and an abrasion of the labia minora; tests, however, were negative for spermatozoa.
The accused pleaded alibi and denial. He claimed the lot was his brother Ricardo’s, that he was at his own house about one-half kilometer away resting at the time alleged, and that he had been at Ricardo’s lot only in the morning. Ricardo Bato and accused’s daughter Lea Grace corroborated that the wards sometimes stole fruit from the lot and that the accused was not present at the relevant time. The trial court found the prosecution witnesses credible, rejected the alibi, and on April 17, 1998 convicted the accused of statutory rape and sentenced him to reclusion perpetua.
The accused appealed to the Supreme Court. He contended the trial court erred in crediting the prosecution’s witnesses despite alleged inconsistencies (location of properties, whether Delia was already in Ricardo’s property wh...(Pro-only)
Issues:
- Did the trial court err in convicting accused-appellant despite alleged inconsistencies in the prosecution witnesses’ testimonies and the medico-legal finding of no spermatozoa?
- Did the trial court err in rejecting accused-appellant’s defense of alibi?
- Should civil indemnity and moral damages be awarded to the victi...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)