G.R. No. 133385 - People vs. Delos Reyes

Maritess Collo, the victim, is the third of five children born to Evelina Punzalan and Mario Collo, and she was born on October 8, 1983 in BiAan, Laguna.
The victim’s familial situation was disrupted due to Evelina’s illicit relationship with accused-appellant Pablito delos Reyes, which led to Mario Collo leaving the family.
Following the separation, Pablito delos Reyes moved into Evelina’s house, thereby assuming a stepfather-like role with Maritess, who came to call him "Kuya Ambo."

On June 12, 1995, at approximately 4:00 in the morning, while Maritess was asleep in the living room, she experienced unwanted advances by Pablito delos Reyes.
Without the presence of her mother, who was away at the market, Maritess’ vulnerability was exploited:

The perpetrator forcibly removed Maritess’ shorts and underwear.
Pablito delos Reyes then removed his briefs and inserted his penis into her vagina, despite her pleas to stop, forcing the act with violence and intimidation.
Maritess experienced severe pain, cried, and later observed blood during urination—an indication of physical injury.

Fearing reprisal after being threatened by Pablito with harm against her family should she report the incident, Maritess initially kept the ordeal to herself.
The following day, she confided in her cousin, Eya, who relayed the matter to her brother Rey and eventually to her father, Mario Collo.
Upon hearing the accounts, Mario took Maritess to a health center where Municipal Health Officer Dr. Soledad Rosanna Cunanan examined her.
The medical certificate issued stated the presence of an old healed hymenal laceration in her genitalia at the 5:00 o’clock position, suggesting prior sexual coitus.

Based on the complaint, Pablito delos Reyes was charged with rape—allegedly committing the act on or about June 12, 1995, in Sta. Rosa, Laguna—under Criminal Case No. 9615-B.
Although the Information mistakenly alleged that the victim was thirteen years old (while she was actually below twelve at the time of the assault), the prosecution established the crime as one involving force, violence, and intimidation.
The Regional Trial Court of BiAan, Laguna, Branch XXV found Pablito delos Reyes guilty beyond reasonable doubt of rape, additionally noting the aggravating circumstance that he was the stepfather of the victim.
The accused was sentenced to reclusion perpetua and ordered to pay the victim moral damages amounting to fifty thousand pesos (₱50,000.00).

Maritess’ detailed and consistent testimony recounting the sequence of events was pivotal to the conviction.
Her statements included precise descriptions such as:

Feeling a “gumagapang na kamay” (crawling hand) on her thigh.
Her attempts to resist by crying and pleading “ayaw ko” (I do not like).
The physical acts of kissing, fondling, and forceful removal of her clothing, culminating in the non-consensual insertion of his penis.

The Medical report confirming the presence of an old yet indicative healed hymenal laceration further substantiated the occurrence of prior sexual activity despite the absence of fresh injuries.

The accused-appellant denied the charges, asserting that he “loved” the victim and contesting the location of the alleged crime by claiming that the building (shanty) had already been demolished on the date of the incident.
The appellate court noted that denial alone is an inherently weak defense, particularly in light of the victim’s positive identification and the physical evidence provided by the medical report.

Whether the prosecution was able to establish the guilt of Pablito delos Reyes beyond reasonable doubt despite discrepancies in the victim’s age as stated in the Information.

The Information alleged the victim was thirteen years old, while evidence and testimony confirmed she was below twelve at the time of the offense.
Whether this discrepancy would impact the classification of the offense as statutory rape versus rape committed with use of force and intimidation.

Whether the trial court erred in considering the aggravated circumstance of the accused’s relationship as stepfather to the victim, given that such aggravating circumstance was not expressly alleged in the Information.

Whether the defendant’s defense—asserting actions motivated by love and the claim concerning the demolition of the shanty—was sufficient to create reasonable doubt regarding his guilt.

The sufficiency and credibility of the victim’s testimony in corroboration with the medical evidence, and its impact on the overall evaluation of the case.