Case Digest (G.R. No. 107204)
Facts:
People of the Philippines v. Benito Salinas y Sillo, G.R. No. 107204, May 06, 1994, the Supreme Court First Division, Cruz, J., writing for the Court.The plaintiff-appellee is the People of the Philippines; the accused-appellant is Benito Salinas y Sillo. The criminal information charged Salinas with the rape of a 13-year-old girl, Merly Alonzo.
On the early morning of December 19, 1991, Merly testified she was awakened in her second-floor bedroom by the sound of a closing terrace door and immediately recognized Salinas by the light in her room. She alleged Salinas covered her mouth, threatened her with a fan knife, removed his clothing, ordered her to lie down, forcibly removed her garments, groped and kissed her, and attempted penile penetration; she managed to resist by pulling his hair and turning on her side, but the head of the penis entered and she experienced intense pain. Salinas allegedly threatened to kill her if she reported the incident and then jumped down from the terrace holding his briefs.
Merly did not report the incident immediately; she told her brother two days later and the family subsequently reported the incident to authorities. Merly underwent a medico-legal examination by Dr. Ma. Cristina B. Freyra of the Crime Laboratory in Camp Crame, who testified there were no external signs of violence and that the hymen need not be torn for penetration to have occurred.
An information for rape was filed in the Regional Trial Court of Manila. At trial the prosecution presented Merly’s testimony and the examining physician’s report. Salinas pleaded alibi: he testified he was sleeping in his house at the time and his sister, Glenda, corroborated that he was asleep on the sofa and that she left at 4:00 a.m. after returning from a party; Salinas also suggested Merly had earlier suspected him of peeping and might have fabricated the charge.
Judge Domingo D. Panis of the Regional Trial Court of Manila found Salinas guilty beyond reasonable doubt and, on August 14, 1992, sentenced him to reclusion perpetua and ordered civil i...(Subscriber-Only)
Issues:
- Did the prosecution prove the guilt of the accused beyond reasonable doubt so as to overcome the constitutional presumption of innocence?
- Does the absence of external injury and an intact hymen preclude a finding of rape where partial penetration is alleged?
- Was the accused’s alibi sufficient to create reasonable doubt a...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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