A.C. No. 4763 - Gamilla vs. Marino, Jr.

On or about April 17, 2000, in the municipality of San Miguel, province of Bohol, the prosecution charged that the accused, Leonardo Castrodes (alias "aAdoka"), committed rape against AAA, a 15-year-old minor.
According to the Information, the accused, with "lewd designs" and by means of force and intimidation, forcibly inserted his penis into the victim’s vagina, contrary to Article 335 of the Revised Penal Code as amended by Republic Act No. 7659.

At around 10:00 a.m., while AAA was gathering firewood on a coconut plantation near the residence of her aunt (BBB) and uncle (CCC), she was unexpectedly accosted by Castrodes.
The accused allegedly wrested the bolo AAA was using, embraced her, and carried her to a spot beneath a coconut tree.
Under threat and intimidation with the bolo, Castrodes is said to have started kissing AAA, caressing her breasts, and forcing her to lie on the ground before removing both her and his clothing.
Despite AAA’s attempts to evade him by squirming, Castrodes reportedly penetrated her, causing pain and provoking her to cry.
After the assault, Castrodes dressed and threatened the victim, warning her to remain silent by promising to kill her and anyone she confided in.

Disturbed by the ordeal, AAA initially kept quiet until later in the day when her uncle, CCC, noticed her distress.
Following a conversation with CCC, AAA disclosed the events, prompting her aunt, BBB, to report the incident to the barangay and have her examined by the Municipal Health Officer.
Notably, the medical report did not reveal vaginal lacerations.

The accused, Castrodes, pleaded not guilty, and his defense presented an alibi stating that on April 17, 2000, he was not at the scene of the alleged crime but was instead at a farm.
His first cousin, Jovenciano Castrodes, testified that:

The accused left his house at around 6:30 a.m. and walked towards the farm.
He and the accused worked on the farm from approximately 7:00 a.m. until about 5:00 p.m., with only a brief interruption for lunch.
They returned together to the house, thereby providing the defense with a continuous alibi for the entirety of the day.

The Regional Trial Court (RTC) convicted Castrodes of rape (Crim. Case No. 00-731), sentencing him to reclusion perpetua and ordering payment of damages to the victim.
The Court of Appeals (CA) affirmed the RTC’s decision, modifying certain aspects (including the quantum of damages) and rejecting the defense’s challenges to the victim’s credibility, the delayed report, and the alibi.

The prosecution’s evidence rested heavily on the victim’s testimony and the corroborative statements of her relatives, notably CCC.
The defense attempted to undermine the credibility of the victim by citing inconsistencies such as:

Whether the crime of rape, as charged, requires the act to be committed in seclusion or whether it can occur in a public or highly visible place.
Whether the delay in the victim’s reporting of the rape incident undermines her credibility as a witness.
Whether the defense’s alibi, indicating that Castrodes was at a farm 20 minutes away from the scene during the time of the alleged rape, is sufficient to create a reasonable doubt regarding his presence at the crime scene.
Whether the lack of vaginal lacerations on examination negates the possibility of rape or significantly weakens the prosecution’s case.
Whether the prosecution’s reliance on the victim’s testimony and corroborative evidence from relatives adequately establishes the guilt of the accused beyond reasonable doubt.