Title
People vs. Castrodes
Case
G.R. No. 206768
Decision Date
Dec 3, 2014
A 15-year-old minor was raped by accused-appellant in a coconut plantation; despite defense claims of alibi and delayed reporting, the Supreme Court upheld the conviction, emphasizing trauma, credibility, and the irrelevance of medical findings.

Case Summary (G.R. No. 101858)

Applicable Law

The case is governed by Article 335 of the Revised Penal Code, as amended by Republic Act No. 7659, and further elucidated by Republic Act No. 8353, which pertains to the crime of rape and its penalties.

Summary of the Prosecution’s Case

On April 17, 2000, at approximately 10:00 AM, AAA was gathering firewood in a coconut plantation near her home when Leonardo Castrodes approached her. He forcibly seized the bolo she was using and carried her to a secluded spot under a coconut tree. Despite her attempts to resist due to fear of being harmed, Castrodes physically overpowered her, removing both their clothing and attempting to penetrate her. AAA struggled, cried out in pain, and felt threatened when he warned her against disclosing the incident. She remained silent until April 26, 2000, when her uncle discovered her distress and encouraged her to report the crime.

Introduction of the Defense

In contrast, Castrodes, supported by his cousin Jovenciano Castrodes, claimed an alibi, stating he was at a farm working at the time of the incident. They depicted a detailed timeline asserting that he could not have been present at the site of the alleged crime.

Trial Court Findings

The Regional Trial Court (RTC) found Castrodes guilty beyond a reasonable doubt of rape, sentencing him to reclusion perpetua and ordering him to pay damages to AAA. The decision highlighted the gravity of the crime and the trauma inflicted on the minor victim.

Court of Appeals Decision

The Court of Appeals (CA) upheld the RTC's decision with modifications. It dismissed Castrodes' assertions questioning AAA's credibility, emphasizing that young victims often do not fabricate such grave allegations and typically face societal ramifications when disclosing such offenses. The CA noted that the delay in reporting the incident was not unusual for a victim of rape, particularly a young girl.

Ruling on Alibi and Evidence

The CA found inadequacies in Castrodes' alibi, adjudging it insufficient to establish his physical unavailability at the crime scene given its proximity. Furthermore, the court reiterated that the abse

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