G.R. No. 129533 - People vs. Pedres y Buag

The case involves the crime of rape committed by Antonio Pedres y Buag against his daughter, Maribel M. Pedres.
The offense was charged under Article 335 of the Revised Penal Code in relation to Section 11 of Republic Act No. 7659.
The incident allegedly occurred on January 5, 1996, at Barangay Macalidong, Municipality of Ligao, Province of Albay, Philippines.

The complaint was filed by Maribel Pedres, with the assistance of her aunt, Julita M. Garcia.
The information stated that the accused, with “lewd design” and by employing force and intimidation, committed rape on his own daughter.
The charge emphasized that the act was a grave violation of the moral ascendancy of the accused as a father.

Maribel Pedres testified that on the night of January 5, 1996, while sleeping with her two brothers, she was awakened by the sensation of someone on top of her who proceeded to tie her hands and feet.
Maribel identified the assailant as her father, who removed her short pants up to her ankle and raped her.
The testimony recounts that after the incident, Maribel exhibited signs of physical trauma, including healed lacerations in the vaginal orifice, as evidenced by a subsequent medical examination by Dr. Maria Nimfa Joji QuiAones.
Additional testimonies by Maricel (Maribel’s older sister) provided supporting evidence regarding the aftermath of the incident, including the sister’s actions to have Maribel medically examined.
The medical findings, noted in Exhibit “A”, described lacerations at positions corresponding to 1:00 o’clock, 11:00 o’clock, and 7:00 o’clock, as well as other distinctive changes in the genitalia.

The accused pleaded not guilty and presented an alibi, claiming he was working at a rice field in Bagsa, Oas, Albay from January 4 until January 7, 1996.
Testimony from his sister, Angelita Bron, and his brother-in-law, Norberto Bulacan, corroborated his presence in the ricefield during that period.
The defense argued that the logistics of transportation between Bagsa (Oas) and Macalidong (Ligao) made it impossible for him to have been at the alleged crime scene.
Additional defense contentions included claims regarding inconsistencies in the complainant’s narrative, such as the absence of resistance, the removal of her garment without tearing it, and the delayed reporting of the incident.

The trial court summarized the testimony of the accused, outlining his account of events on January 4–7, 1996, including details about drinking with relatives and working on a farm.
The court evaluated both sets of testimonies, noting especially the emotional and physical evidence supporting the complainant’s version of events.
Despite the defense’s emphasis on alleged inconsistencies and the strength of the alibi, the trial court found the prosecution’s evidence sufficient to prove guilt beyond reasonable doubt.

The trial court rendered a decision convicting the accused for rape, imposing the death penalty and ordering him to indemnify the victim with ₱50,000.00.
The case was elevated to the appellate level for automatic review, where issues regarding the credibility of evidence and the sufficiency of proof were raised by the accused-appellant.

Whether the trial court erred in accepting the allegedly uncorroborated testimony of the complainant, given certain inconsistencies pointed out by the defense.
Whether the complainant’s delayed reporting and behavioral inconsistencies, such as not summoning her siblings during the assault, undermine her credibility.

Whether the accused’s defense based on his alibi, supported by testimonies from his relatives, established a plausible alternative narrative that could create reasonable doubt.
Whether, given the inherent weaknesses of an alibi raised by the accused and his immediate relatives, such defense should be accorded significant weight in the face of positive identification by the victim.

Whether the imposition of the death penalty was proper under the circumstances, considering the legal framework and applicable qualifications (especially regarding the victim’s age).
Whether the penalty mandated should be adjusted in light of the applicable legal standards (e.g., conversion to reclusion perpetua).