G.R. No. 188669 - People vs. Mendoza y Berizo

On May 28, 2003, in Muntinlupa City, Philippines, Ildefonso Mendoza was charged with Statutory Rape under Article 266-A of the Revised Penal Code, as amended by R.A. 8353.
The Information alleges that Mendoza, by means of force, threat, or intimidation, willfully committed carnal knowledge of the victim, identified as CMS, an eight-year-old girl, by pressing his penis into her vagina for the purpose of penetration despite her will and consent.

CMS narrated that the accused removed her shorts and panty, kissed and licked her vagina, and then inserted his penis into her vagina.
She experienced significant pain and cried out “Aray!” prompting the accused to withdraw his penis.

At about 2:30 p.m., while CMS was at home in the sala, Anna Loth, who was eight years old at the time, was positioned on the second floor of an adjacent house.
Through a hole in the wall, she observed a moving blanket covering the lower body of Mendoza.
She saw Mendoza pulling CMS’s feet, removing her shorts, and kissing her vagina as she attempted to escape.
Alarmed by what she witnessed, Anna Loth summoned her cousins, siblings, and CMS’ brother, Joseph, who also observed the incident.

CMS’s account was further detailed using anatomical drawings (paper dolls) to indicate the exact sequence of actions committed by Mendoza.
Anna Loth’s corroborative testimony provided additional verification regarding the physical actions of the accused, reinforcing the occurrence of the offense.

Mendoza’s sole testimony maintained that, on the said day, he was asleep at the house of Romeo Serrada due to a fever and thus incapable of committing the alleged act.
He claimed that he was awakened much later in the evening by unrelated circumstances and was subsequently informed of the charges against him only the following day at the Barangay hall, where he experienced physical abuse (being kicked).
The defense failed to produce any supporting evidence or corroborative witnesses who could confirm his alibi.

The Regional Trial Court (RTC), Branch 207, Muntinlupa City, found Mendoza guilty beyond reasonable doubt of statutory rape.

The RTC found significant credibility in the testimony of CMS—a minor whose clear, spontaneous, and coherent account was given full weight.
The court emphasized the witnesses’ immediate and earnest reporting of the incident, particularly noting the role of Anna Loth and the victim’s family.

The Court of Appeals (CA) affirmed the RTC’s decision, upholding the guilt determination based on the strength of the prosecution’s evidence and witness testimonies.

Whether the detailed, coherent testimonies of CMS (the minor victim) and Anna Loth (eyewitness) were sufficient to establish, beyond reasonable doubt, that Mendoza committed statutory rape.
Whether the indictment for rape, which is based predominantly on testimonial evidence, can withstand challenges regarding its inherent evidentiary difficulties.

The issue of the credibility of the complainant’s testimony, taking into account her age, lack of worldly experience, and the corroborative detailed account using anatomical drawings.
Whether the consistent observations by an independent eyewitness serve to reinforce the prosecution’s narrative despite the accused’s barefaced denial.

Whether the accused’s claim of being asleep due to a fever, which lacked any corroborative evidence or supportive witness testimony, was sufficiently credible to create reasonable doubt.