G.R. No. 179793 - Hidalgo vs. Republic

On August 11, 1991, at around 7:00 p.m., in Barangay Dobdob, Valencia, Negros Oriental, Clara Angcon, a 51-year-old widow and farmer, was alone in her house weaving a mat when the accused, Inoferio Venerable alias Porferio Venerable, appeared.
The accused, known in the community and recently released from jail for a previous offense, initially asked for water and food before perpetrating his crime.
The criminal charge was filed by the 4th Assistant Provincial Prosecutor Rodrigo V. Icao, based on Clara’s sworn complaint, charging the accused with rape under Article 335 of the Revised Penal Code.

The accused first asked for water and food. After leaving briefly, he returned and, while Clara was handing him a match, he grabbed her forearms and forcibly pushed her into the kitchen.
In the kitchen, he overpowered her—wrestling her to the floor, forcing her to lie face-up—and then used a bolo, while removing her garment and exposing his penis.
The accused then committed four successive acts of forcible sexual intercourse. Each act was marked by violent restraint, physical overpowering, and explicit force, all amidst the victim’s pleas and shouts for help.
Throughout the incident, the complainant’s struggle and distress were evident, though isolated in a remote setting where immediate help was not available.

Clara Angcon, traumatized and physically affected by the ordeal, delayed her medical consultation because of the distance to the nearest clinic and fear of retribution by the accused.
On August 26, 1991, she was examined by Dr. Fe L. Besario at the Rural Health Office in Valencia. The examination revealed a hematoma on her left arm and noted the absence of vaginal lacerations or seminal fluids—findings explained by the elapsed fifteen-day period before examination.
The medico-legal logbook and associated exhibits from both the prosecution and defense recorded her testimony and the doctor’s observations.

The Regional Trial Court in Dumaguete City, Branch 34, meticulously gathered the testimonies of Clara Angcon, Dr. Besario, and the defense witness, Teresita Alabata Venerable (the accused’s sister-in-law).
While the prosecution’s evidence rested on the consistent and credible account of the victim and supporting forensic findings, the accused and defense presented an alibi and a “sweetheart” theory.
The alleged alibi by the accused was inconsistent; he initially claimed to have been resting at home in Dobdob after arriving from Malaunay, then later testified having worked on the family farm, and finally reverted to claiming he had been at home.
The defense witness testified that the accused was in Malaunay stripping abaca, though this was insufficient to establish a reliable alibi given the proximity (approximately two kilometers) between his residence and the victim’s house.

Whether the trial court erred in assigning evidentiary weight to the victim’s testimony given its perceived inconsistencies or emotional nature.

The accused contended that the victim’s account was unreliable, unworthy, and incredible.
The defense argued that the inability of the victim to recall every detail should diminish the credibility of her testimony.

Whether the defense’s evidence, including the alibi and the “sweetheart” theory, should have been given exculpatory weight.

The accused’s theory suggested a prior consensual relationship between him and the victim, claiming that they had engaged in sexual relations on other occasions, though not on the incident day.
The credibility of the defense witness and the accused’s own inconsistent testimony raised doubts regarding the proper assessment of his whereabouts at the time of the crime.

Whether the prosecution was able to prove the accused’s guilt beyond reasonable doubt despite the lack of corroborative forensic evidence (e.g., the absence of seminal fluids in the victim’s examination).

The delay in the victim’s medical examination was noted and considered within the context of the geographical and situational difficulties she faced.
The court had to determine if the medical findings, together with the victim’s testimony and the circumstantial evidence, were sufficient to establish the crime of rape.