G.R. No. 224888 - People vs. Ramelo

Accused-appellant Winston de Guzman was charged with the crime of rape for allegedly having carnal knowledge of 14-year-old complainant Jovelyn A. Geram.
The incident occurred on or about June 9, 1994, in the Municipality of Governor Generoso, Davao Oriental.
The Regional Trial Court of Mati, Branch 5, Davao Oriental, had jurisdiction over the case, originally docketed as Criminal Case No. 2584.

The complainant, Jovelyn A. Geram, was at home alone at Barangay Monserrat when the accused gained entry into the house.
In the afternoon around two o’clock, while she was sleeping, complainant was awakened by the weight of a body, finding de Guzman naked and sitting on her thighs.
The accused reportedly used force, violence, and intimidation; at one point, he covered her mouth and nose to silence her attempts to call for help.
A struggle ensued, during which the complainant sustained injuries evidenced by blood and white fluid, consistent with physical trauma to her genitals and other parts of her body.

Immediately after the incident, a neighbor, Florami Bayno, arrived at the Gerams’ residence, after which the complainant sought refuge and later recounted the incident to friends and family.
The complainant confided in several individuals including a neighbor (Genesis Delgado) and a teacher (Enecita dela Cruz Torion), who testified to observations that placed de Guzman at or near the scene.
A medical examination at the municipal hospital conducted by Dr. Divina Lopez revealed findings such as blood clots on the labia minora, a ruptured hymen, and redness around the vulvar area.

Prosecution witnesses provided direct and circumstantial evidence linking the accused to the scene—testimonies included observations of his entry and exit from the complainant’s residence.
Testimonies confirmed that the crime was committed under conditions of force and intimidation, despite later attempts by the accused to assert a different account.
The defense’s evidence rested on a denial and an alibi, claiming that de Guzman was in Davao City with his mother, attending to family matters.
The only witnesses supporting the defense were the accused’s parents, whose testimonies were perceived as self-serving and uncorroborated by other independent witnesses.

The prosecution introduced evidence of the complainant’s detailed account, including her immediate report of the incident to authorities and relatives.
The defense later attempted to impeach the credibility of the complainant by pointing to alleged inconsistencies between her testimony during the preliminary investigation and at trial.
Specifically, the accused argued that prior statements indicated that he had used odorous chemicals to induce sleep, a detail which was omitted in the trial testimony where force and intimidation were alleged instead.
The accused’s counsel also attempted to use the complainant’s complaint document, which had not been formally introduced or discussed during the trial, to challenge her credibility.

Whether the trial court committed an error in giving full credence to Jovelyn’s testimony, despite the defense’s claim of inconsistencies with her preliminary statements.
Whether the alleged contradictory statements—particularly regarding the use of sleep-inducing chemicals versus the application of force—were sufficient to undermine her account.

Whether the defense properly established the required predicate or foundation to impeach the complainant’s credibility by pointing out inconsistencies in her prior extrajudicial statements.
Whether the accused’s counsel violated evidentiary rules by introducing discrepancies that were neither formally presented nor explained during the trial.

Whether the complaint document, which contained the disputed statements, could be used to impeach the complainant’s testimony despite not being part of the trial’s evidence or having been shown to the complainant for her explanation.