Case Summary (G.R. No. 150382)
Incident Overview
The events transpired on September 1, 1996, in Natuel, Buguias, Benguet, when AAA was en route to her parents' home in Tinoc, Ifugao, to collect her allowance. While walking, she encountered Basite, who attacked her after following her a short distance. Using a knife to threaten her, he forcibly undressed her and sexually assaulted her. After the assault, AAA managed to stab Basite and subsequently lost consciousness after rolling down a cliff.
Medical Examination and Initial Report
After the incident, AAA regained consciousness and made her way home, where she reported the rape to her relatives and subsequently filed a formal complaint. A medical examination revealed injuries that were inconsistent with her account of the assault, including no lacerations or signs of trauma to her vagina despite her claim of rape. The results indicated an intact hymen and other bodily scrapes, leading to conflicting narratives regarding the nature of the assault.
Accused's Defense
Basite denied the charges and brought witnesses, including Lidot Lacbao and Dr. Ronald Bandonill, who challenged AAA's credibility. Lacbao claimed that AAA denied being raped when she spoke to him shortly after the incident. Dr. Bandonill criticized the inadequacy of the medical examination report, arguing that a lack of physical signs of intercourse suggested no sexual act occurred.
Trial Court's Findings
The trial court assessed the case based on AAA's testimony, which was described as spontaneous and consistent, ultimately determining that it warranted conviction despite medical findings that did not comprehensively support the occurrence of rape. It established that the credibility of the victim’s account and her positive identification of Basite as her attacker were critical factors in the ruling.
Appeal and Appellate Court's Decision
In his appeal, Basite contended that reasonable doubt was created by the trial court’s acknowledgment of the shortcomings of the medical certificate. He also questioned the consistency of AAA's statements with those of witness Lacbao. The appellate court reiterated that in cases of rape, the testimony of the complainant can stand alone if found credible.
Conclusion of the Ruling
The appellate court concluded that despite the lack of corroborating medical evidence, AAA's testimony was credible and sufficient to
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Case Background
- Nature of the Case: The case concerns the conviction of Eddie Basite for simple rape, sentenced to reclusion perpetua, and ordered to pay damages.
- Appellant: Eddie Basite
- Appellee: People of the Philippines
- Decision Date: October 02, 2003
- Trial Court: Regional Trial Court, Branch 64, Abatan, Buguias, Benguet
- Complainant: AAA, a 19-year-old polio victim and student of midwifery.
Incident Details
- Date of Incident: September 1, 1996
- Location: Natuel, Buguias, Benguet
- Context: AAA was walking to her parents' home in Tinoc, Ifugao, to collect her allowance when she encountered Eddie Basite.
- Assault Description:
- After an initial encounter, Basite followed AAA, threatened her with a knife, and forced her to the ground.
- He undressed and raped her, despite her resistance and pleas.
Victim's Response and Aftermath
- Immediate Reaction: After the assault, AAA seized the knife and stabbed Basite before he fled the scene.
- Physical State: AAA rolled down a cliff, lost consciousness, and upon waking, felt extreme pain and confusion.
- Subsequent Actions:
- AAA made her way home by moonlight, encountered soldiers who offered assistance, and later recounted her ordeal to relatives, leading to a police report.
Legal Proceedings
- Initial Reporting: AAA filed a complaint at the Abatan Police Station, detailing the assault.
- Medical Examination: Conducted at Abatan Emergency Hospital, revealing no lacerations or bleeding but multiple scratches and contusions.
- Court Filings: An Information for Rape was filed on October 2, 1996, with Basite pleading not guilty.
Testimonies and Evidence
Prosecution Evidence:
- AAA’s Testimony: Detailed, emotional account identifyi